DSHW-2024-007414

COMPLIANCE EVALUATION INSPECTION REPORT

INSPECTION REPORT FOR: Blanchard Metals Processing Corporation
DATE OF INSPECTION: 4/30/2024
FACILITY ADDRESS: 1115 South Pioneer Road
Salt Lake City, UT 84104

FACILITY COUNTY: Salt Lake
FACILITY CONTACT: Rich Madsen
Quality Manager
[phone]
EPA ID #: UTD009099987
LATITUDE/LONGITUDE: 40.745880902300314, -111.95721746884684
GENERATOR STATUS: LQG
NUMBER OF EMPLOYEES: 72
ARRIVAL/DEPARTURE TIME: 12:50 PM/4:15 PM
WEATHER CONDITIONS: Sunny, 60s
PARTICIPANTS: Judy Moran & Sally Kaiser, DWMRC
Rich Madsen, Quality Manager, Blanchard Metals
Processing

REPORT PREPARED BY: Judy Moran
LHD NOTIFICATION DATE: April 16, 2024
FACILITY NOTIFICATION DATE: April 16, 2024
APPLICABLE REQUIREMENTS: R315-260 through 273, R315-15 of the Utah
Administrative Code (UAC)
CREDENTIALS, PURPOSE AND SCOPE:
The purpose of this Compliance Evaluation Inspection was to evaluate the facility's waste
management practices for compliance with applicable rules under R315 of the Utah
Administrative Code and the Utah Solid and Hazardous Waste Act 19-6-101.
Upon our arrival we presented our credentials to the receptionist, signed in and asked for Rich
Madsen. Rich Madsen met us in the lobby and directed us to a conference room.
I mentioned that their last inspection was with Rebecca Smith back in 2020 when they received a
warning letter which was later closed out, but that I could not find the corrective action
documentation in our files. Rich showed me his notes documenting attempts to contact Rebecca
(Photo 1). I explained she no longer worked for the Division and explained that communications
about corrective actions should go through the DEQ’s official submittal portal, with a copy to
me.
FACILITY DESCRIPTION:
Blanchard Metals Processing is a family-owned business that has been in operation since 1967
and since 1978 in this location. Blanchard heat treats, uses chemical conversion processes,
anodizes, performs cadmium plating and paints aerospace and military parts. Blanchard also
performs non-destructive testing. Most of the parts that Blanchard treats are aluminum or steel,
and occasionally brass or copper parts. Their biggest clients are aerospace companies such as
Williams International, SpaceX, and Northrop Grumman.
MANAGEMENT ACTIVITIES:
Blanchard operates a wastewater treatment system with a discharge permit issued by Salt Lake
City.
Blanchard generates F006 filter cake from its wastewater treatment system; cadmium carbonate
when its cadmium plating solution becomes spent; spent chromic acid when its chrome plating
solution becomes spent; electroless nickel strike, sodium dichromate, and sulfuric anodize when
the solutions becomes spent and a tank must be emptied. Sodium cyanide is used in the cadmium
plating process.
Blanchard ships hazardous waste offsite for disposal approximately every four months.
Blanchard uses cotton swabs to clean parts with methyl ethyl ketone (MEK). At the time of the
inspection Blanchard was throwing the used cotton swabs in the regular garbage. As of June 27,
2024, they were managing the used swabs as exempt solvent wipes.
Blanchard uses MEK to clean pain guns and other painting equipment. At the time of the
inspection, they were allowing the spent MEK to evaporate and disposing of the residue in the
regular garbage. As of June 27, 2024, they were managing the spent MEK as hazardous waste in
a satellite accumulation area.
NARRATIVE:
We began our walkthrough in the heat-treat area. No hazardous waste is generated from the heat-
treating process. We moved on to the Chem Film line and saw the rinse water agitator (Photo
10). Wastewater is piped from the agitator to the wastewater treatment system. Hazardous waste
is generated from this process if a process tank becomes spent.
The Masking Room is adjacent to the Chem Film line. Rich Madsen said that no hazardous
waste was generated from this process. Later while discussing waste generation in the paint area
we learned that Blanchard uses cotton swabs to clean parts with methyl ethyl ketone (MEK) in
the Masking Room.
We saw four drums identified as waste oil on a secondary containment pallet (Photo 11). Rich
confirmed that the contents are managed as used oil. I instructed him to relabel the containers
“used oil” and to send me a photo.
On our way to the wastewater treatment area we saw a drum of soda ash, used to neutralize acid
spills (Photo 12).
We moved on to the wastewater treatment area. Blanchard’s wastewater treatment system
consists of rinse holding tanks, used process solution tanks, and a filter press. (Photos 13-18) We
saw a small amount of F006 hazardous waste filter cake on the floor under the filter press. I
instructed Rich to have it cleaned up and send me a photo of the cleaned area. F006 filter cake is
accumulated in a roll-off container outside at the south end of the property. The roll-off was
closed, labeled hazardous waste, and the accumulation date was marked on the container. The
container was not labeled or marked with an indication of the toxic hazard of the contents.
(Photo 19) Rich wrote “toxic” on the container while we were there. (Photo 20)
We next observed a tote full of Used Oil, but it was not labeled Used Oil. We observed three
drums of non-hazardous waste on secondary containment.
Paint Room
We asked Rich how they managed their rags. Rich said that the MEK evaporates and they throw
the rags in the regular garbage. I took a photo of paint stir sticks sitting in a can with either
thinner, MEK, or both. We saw two containers under the table. One contained rags and other
paint-related debris and the other one contained spent MEK that is allowed to evaporate, and
then the resulting solid material is thrown in the regular garbage. We asked Rich to lift off the
spout and saw that it was about 3/4 full of MEK.
I asked about metals in any of the paints. Rich left to ask Collin Buck, Quality Assurance Rep
for the paint area to join us. Collin said that they use chromium-free paint. They use the MEK
to clean the paint guns. I explained to them that they can’t let it evaporate because it is hazardous
waste. I instructed Rich to label the container “hazardous waste,” ensure that it remained closed
expect when in use, and then when full, dispose of it as hazardous waste.
We went to look at how they manage the swabs in the masking area. (Photo 28) They are also
left to dry and then thrown in the regular garbage. (Photo 29) I explained that the swabs are
hazardous waste or that they could be managed under the solvent wipes exclusion and promised
to send them additional information.
Weekly Central Accumulation Area Inspections
We reviewed inspection records on the big screen. They are done every Monday or the next day
if a holiday is involved. Rich Madsen completes the inspections.
Manifests and LDRs
Sally reviewed hazardous waste (HW) manifests from July 2020 through 12/28/2023.
We had questions about some of the HW manifests.
• 016050821FLE – Cathy Soffel had scratched out her own name, initialed and then re-
signed on same day. (Photos 7&8)
• 016047655FLE – ok final page completed electronically
• 017109304FLE (with 017110776FLE) – Chad Kerr signed
• 014089344FLE – rejected at CHA and sent to NV
• 014089196FLE – Gary Mosser (of AET) signed for Blanchard. Rich said that Gary calls
in each instance that they sign the HW manifests or do a manifest transfer, asking
permission to do so.
• 016050821FLE – split to 017109107FLE
Rich told us that high cyanide waste takes a long time to accumulate, and disposal generally
takes a long time as well. I explained that transfer facilities only have 10 days and yet the
transporter Blanchard contracts with had told Rich they could take as long as six months to get
Blanchard’s waste to the destination facility. I explained exception reports to Rich and advised
that Blanchard should confirm that the destination facility can take their waste prior to turning
their waste over to the transporter. I explained the process to request an accumulation time
extension if the destination facility could not take their waste in a timely manner.
We found one manifest that required an exception report, #017110776FLE (Photo 6). I asked
Rich to reach out to the transporter and ask them why they transferred the waste from manifest
#017109304FLE (Photo 5) to manifest #017110776FLE (Photo 6) and where the waste was
stored between the time it was picked up on 1/6/23 and when Ana Lopez, US Ecology in Beatty
NV signed manifest #017110776FLE on 7/31/23. Neither manifest is in EPA's electronic
manifest system so it is important to learn where the waste was over those 7 months, and to
verify that it was actually received at US Ecology in Beatty NV.
Rich submitted this information on June 27, 2024:
I reached out to Gary Mossor, the Head of Operations, at AET who informed me that the waste
on manifest 017109304FLE, when initially picked up at Blanchard, was planned on being
treated at Clean Harbors in Aragonite Utah. However, on February 21st, Clean Harbors
notified them there was a hold on their shipping incinerator and would not be able to pick it up.
He explained that AET then kept the 3 drums on their transporter and it moved between the Salt
Lake, Denver & Las Vegas locations, as to not violate the 10 day holding requirement, until US
Ecology agreed to accept the material July 11, at which time it was transferred to
017110776FLE. If you have any additional questions, he was more than happy to speak with
you.
Contingency Planning & Emergency Response
Blanchard has prepared a hazardous waste contingency plan (CP) and quick reference guide
(QRG). Blanchard’s CP and QRG included most of the required elements.
The following deficiencies were noted:
• UAC R315-262-262(b)(6): the nearby fire hydrant (not owned or maintained by
Blanchard) flow rate was not listed in the QRG;
• UAC R315-262-262(b)(8) and UAC R315-262-261(d): one of the individuals (Kerry
Bertelson) listed as an alternate emergency coordinator no longer works for Blanchard;
• UAC R315-262-261(e): The contingency plan did not include the required list of
emergency equipment and the location of the equipment.
• UAC R315-262-261(f): The facility evacuation plan was posted on the walls but was not
included in the hazardous waste contingency plan provided for our review.
I explained to Rich Madsen that he would need to update Blanchard's contingency plan with the
list of emergency equipment, where the equipment is located, an evacuation plan, and remove K.
Bertelsen.
Training
Blachard contracts with RMEC to provide their employee training. We reviewed the training
content from RMEC on the big screen. We noted that the content was compliant. The date of
their last RCRA training was December 2023.
Rich Madsen, Steve Rij, and Chad Kerr signed the hazardous waste manifests we reviewed. Rich
explained that Department of Transportation (DOT) hazardous material shipping training is
included in the training conducted by the contract trainer that comes onsite to train Blanchard
employees. He and Steve Rij were trained on DOT requirements after the general RCRA training
provided to the rest of the staff. Rich was unable to provide documentation of the DOT training
he described to me. Chad Kerr had not received Department of Transportation (DOT) Hazardous
Material Shipping General Awareness, Function-Specific, Safety, and Security (49 CFR
172.704) training as required for employees who offer hazardous waste for transportation.
I promised to send Rich the DOT training documentation requirements, which I did on May 1,
2024.
Rich Madsen, Steve Rij, and Chad Kerr received HazMat shipping training from Dan Nye of
RMEC on June 21, 2024. Documentation of the training was provided to DWMRC on June 27,
2024 (DSHW-2024-006991).
Follow-up
I sent an email to Rich Madsen noting the following and requesting documentation of corrections
on May 1, 2024. All of the issues have been addressed and documentation was provided to
DWMRC (via dwmrcsubmit) on June 27, 2024 (DSHW-2024-006991).
1. Yesterday we found one manifest that required an exception report, 017110776FLE.
Please reach out to your transporter and ask them why they transferred the waste from
manifest number 017109304FLE to manifest #017110776FLE and where the waste was
stored between the time it was picked up on 1/6/23 and when Ana Lopez, US Ecology in
Beatty NV signed manifest #017110776FLE on 7/31/23. Neither manifest is in EPA's
electronic manifest system so it is important to learn where the waste was over those 7
months, and to verify that it was actually received at US Ecology in Beatty NV.
2. Update Blanchard's contingency plan with the list of emergency equipment, where the
equipment is located, an evacuation plan, and remove Kerry Bertelsen. Send the updated
plan to your local responders and copy me on the email so I know you've sent it to them.
Blanchard’s emergency plan was updated to include a list of emergency equipment
(sections 3.0 & 4.0); the plant layout was revised to show the locations of the emergency
equipment; a detailed evacuation plan was added to section 16.0; and Kerry Bertelsen
was removed from the plan.
3. Label the tote and 4 drums with the words "used oil" and send me a photo. The drums
were relabeled “used oil.” The tote was labeled “sed oil.” Photos were sent.
4. Clean up the very small amount of filter cake on the floor underneath the filter press and
send me a photo. The filter cake was cleaned up off the floor and a photo was sent.
5. Manage rags and swabs used to apply MEK as either F005 hazardous waste or as exempt
wipes that are disposed of (see attached regulatory excerpt) Let me know which option
you have chosen and then send me photos of the swab and rag containers. Rags are not
used with MEK, however cotton swabs are. Four “Justrite” containers were purchased,
labeled and put at the point of use. The Emergency Contingency Plan was updated in
section 18, #4. A photo was sent.
6. Manage spent MEK liquid waste as F005 hazardous waste. The satellite container in
which the spent MEK is being accumulated must be kept securely closed at all times
except when adding or removing waste; the container must be labeled with the words
"hazardous waste" and an indication of the hazards of the contents. You may accumulate
up to 55 gallons of hazardous waste in a satellite accumulation area. Once you have
reached 55 gallons, you must transfer the waste to a central accumulation area within 3
days. The 90-day clock begins when you reach 55 gallons or when you move the
container from the area in which the waste is generated. Send me a photo of the closed
and labeled satellite accumulation container. A flammable cabinet was purchased,
labeled, and a 55-gallon drum placed inside for satellite collection. Section 18, #4 again
describes this in the Emergency Contingency Plan
7. Train all employees (including Chad Kerr) who sign hazardous waste manifests on
Department of Transportation (DOT) Hazardous Material Shipping General Awareness,
Function-Specific, Safety, and Security (49 CFR 172.704). Rich Madsen, Steve Rij, and
Chad Kerr received HazMat shipping training from Dan Nye of RMEC on June 21, 2024.
8. Please provide records that document the training required in 49 CFR 172.704.
Recordkeeping. Each hazmat employer must create and retain a record of current training
of each hazmat employee, inclusive of the preceding three years for as long as that
employee is employed by that employer as a hazmat employee and for 90 days thereafter.
The record must include: (1) The hazmat employee's name; (2) The most recent training
completion date of the hazmat employee's training; (3) A description, copy, or the
location of the training materials used to meet the requirements in paragraph (a) of this
section; (4) The name and address of the person providing the training; and (5)
Certification that the hazmat employee has been trained and tested. Documentation of the
training was provided to DWMRC on June 27, 2024 (DSHW-2024-006991).

COMPLIANCE STATUS: (also see attached checklist)
R315-262-11: Hazardous Waste Determination
Blanchard failed to make a hazardous waste determination on swabs used to clean parts with
MEK.
Blanchard is now managing used cotton swabs under the solvent wipes exclusion.
Documentation was provided to DWMRC on June 27, 2024 (DSHW-2024-006991).
Blanchard failed to make a hazardous waste determination on spent methyl ethyl ketone (MEK)
used to clean painting equipment.
Blanchard is now managing spent MEK as hazardous waste. Documentation was provided to
DWMRC on June 27, 2024 (DSHW-2024-006991).
R315-262-12: EPA Identification Numbers
Satisfactory
R315-262-15 Satellite Accumulation
Satisfactory.
R315-262-17: Accumulation Time
Satisfactory
R315-262-17: Container Management
Satisfactory
R315-262-17: Tank Management
Satisfactory
R315-262-17: Preparedness and Prevention – Training
Blanchard failed to document hazardous materials shipping training employees for employees
who offer hazardous waste for shipment by signing hazardous waste manifests.
Rich Madsen, Steve Rij, and Chad Kerr received HazMat shipping training from Dan Nye of
RMEC on June 21, 2024. Documentation of the training was provided to DWMRC on June 27,
2024 (DSHW-2024-006991).
R315-262-20: Manifest
Satisfactory
R315-262-30 to 33: Packaging, Labeling, Marking, and Placarding
Satisfactory
R315-262-40: Recordkeeping
Satisfactory
R315-262-41: Biennial Reporting
Satisfactory
R315-262-42: Exception Reporting
Hazardous waste shipped on manifest # #017110776FLE did not reach a destination facility
within 45 days and Blanchard failed to submit an exception report to the Director.
Blanchard has subsequently followed up with the transporter (AET) and provided an explanation
in an email submitted to the Division on June 27, 2024 (DSHW-2024-006991).
R315-262-250 through 265: Contingency Plan and Emergency Procedures
The following deficiencies were noted:
• UAC R315-262-262(b)(6): the nearby fire hydrant (not owned or maintained by
Blanchard) flow rate was not listed in the QRG;
• UAC R315-262-262(b)(8) and UAC R315-262-261(d): one of the individuals (Kerry
Bertelson) listed as an alternate emergency coordinator no longer works for Blanchard;
• UAC R315-262-261(e): The contingency plan did not include the required list of
emergency equipment and the location of the equipment.
• UAC R315-262-261(f): The facility evacuation plan was posted on the walls but was not
included in the hazardous waste contingency plan provided for our review.
Blanchard’s contingency plan was revised to correct the deficiencies identified during the
inspection. The revised plan was submitted to the Division on June 27, 2024 (DSHW-2024-
006991).
R315-262-265 and R315-261-420: Spill Response
Satisfactory
R315-268: Land Disposal Restrictions
Satisfactory
R315-15: Standards for the Management of Used Oil
A tote and four drums containing used oil were not labeled “used oil.”
The drums were relabeled “used oil.” The tote was labeled “sed oil.” Photos were sent to DWMRC on
June 27, 2024 (DSHW-2024-006991).
R315-273: Standards for Universal Waste
Satisfactory

FOLLOW-UP ACTIONS:
Closeout letter with violations noted.

INSPECTOR SIGNATURE: ___ DATE: 7/2224

ATTACHMENTS:
1. Photos
2. Inspection Checklist
3. Email correspondence

Attachment 1
Photos

001 4/30/2024 UTR009099987 002 4/30/2024 UTR009099987
Blanchard Metal Processing’s attempts to contact previous
inspector. Blanchard’s Quick Reference Guide.

003 4/30/2024 UTR009099987 004 4/30/2024 UTR009099987
Blanchard’s Quick Reference Guide. Blanchard’s Quick Reference Guide.

005 4/30/2024 UTR009099987 006 4/30/2024 UTR009099987
Manifest #017109304FLE Manifest #017110776FLE

007 4/30/2024 UTR009099987 008 4/30/2024 UTR009099987
Page 1 of 2 of manifest #016050821FLE Page 2/2 of manifest #016050821FLE

009 4/30/2024 UTR009099987 010 4/30/2024 UTR009099987
Manifest #014089344FLE. Rinse water agitator.

011 4/30/2024 UTR009099987 012 4/30/2024 UTR009099987
Used oil not labeled correctly. Soda ash for responding to spills.

013 4/30/2024 UTR009099987 014 4/30/2024 UTR009099987
Wastewater treatment tank. Wastewater treatment tank.

015 4/30/2024 UTR009099987 016 4/30/2024 UTR009099987
Wastewater treatment tank. Emergency evacuation diagram on wastewater tank.

017 4/30/2024 UTR009099987 018 4/30/2024 UTR009099987
Tanks that are part of wastewater treatment system. Wastewater filter press.

019 4/30/2024 UTR009099987 020 4/30/2024 UTR009099987
Roll-off containing F006 hazardous waste, missing indication of
hazard. “Toxic” added to label in previous photo to indicate the hazard of
the contents.

021 4/30/2024 UTR009099987 022 4/30/2024 UTR009099987
Used oil not labeled “Used Oil.” Non-hazardous waste.

023 4/30/2024 UTR009099987 024 4/30/2024 UTR009099987
MEK and thinners used in paint area. Paint stir sticks in thinner or MEK.

025 4/30/2024 UTR009099987 026 4/30/2024 UTR009099987
MEK used to clean painting equipment in paint area. Used MEK in paint area.

027 4/30/2024 UTR009099987 028 4/30/2024 UTR009099987
Dried painting debris (chromium-free). Cotton swabs and MEK in the Masking Area.

029 4/30/2024 UTR009099987
Swabs (used to clean parts with MEK) in a trash can in the Masking
Area.

Attachment 2

Inspection Checklists
INSPECTION WORKSHEET
Facility Name: EPA ID Number:
Street Address: City: Zip:
County: Contact Person: Telephone #:
Generator Status: Number of Employees: Date of Visit:
Evaluators:
Other Personnel:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Code
Estimated Quantity of Hazardous
Waste Generated Per Month
Date: ____________________________________
RECEIVED BY: DWMRC REPRESENTATIVE:
Name: (Printed) ____________________________________________ Name: (Printed) __________________________________
Signature: _________________________________________________ Signature: _______________________________________
Title: ______________________________________________________ Title: ____________________________________________
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Phone [phone]
Fax [phone]
1
Blanchard Metal Processing UTD009099987
1115 South Pioneer Road
Salt Lake Rich Madsen
LQG 72 4/30/2024
Judy Moran, Sally Kaiser
4/30/2024
Judy Moran
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Code
Estimated Quantity of Hazardous
Waste Generated Per Month
NOTES:
2
Previous inspection 7/30/2020, Rebecca Smith. Warning Letter #2008086 with labeling issues, CAA
inspections, contingency plan deficiencies, training deficiencies, couldn't confirm arrangements with
local response orgs. Closed out on Feb 5, 2021.
Blanchard Metals Processing is a metal processing plant which heat-treats, electroplates and
manufactures metal parts, primarily for the military and aerospace industry. Plating operations
encompass a wide range of processes, from anodizing to zinc plating, most of which involve dipping
metal parts into open baths of chemicals.
Hazardous Waste Inspection – Large Quantity Generator Checklist
Inspector’s Initials:
NOTES:
Site EPA ID:Date:

Blanchard Metal Processing UTD009099987 4/30/2024
017109423FLE 1/27/23 017109473FLE 3/14/23 017109456FLE 3/14/23
017110681FLE 6/19/23 017110729FLE 6/19/23 017110780FLE 7/19/23
017112165FLE 12/8/23

Here are the items that require some follow-up:
Yesterday we found one manifest that required an exception report, 017110776FLE. Please reach out to
your transporter and ask them why they transferred the waste from manifest number 017109304FLE to
manifest #017110776FLE and where the waste was stored between the time it was picked up on 1/6/23
and when Ana Lopez, US Ecology in Beatty NV signed manifest #017110776FLE on 7/31/23. Neither
manifest is in EPA's electronic manifest system so it is important to learn where the waste was over
those 7 months, and to verify that it was actually received at US Ecology in Beatty NV.
Update Blanchard's contingency plan with the list of emergency equipment, where the equipment is
located, an evacuation plan, and remove Kerry Bertelsen. Send the updated plan to your local
responders and copy me on the email so I know you've sent it to them.
Label the tote and 4 drums with the words "used oil" and send me a photo.
Clean up the very small amount of filter cake on the floor underneath the filter press and send me a
photo.
Manage rags and swabs used to apply MEK as either F005 hazardous waste or as exempt wipes that are
disposed of (see attached regulatory excerpt) Let me know which option you have chosen and then send
me photos of the swab and rag containers.
Manage spent MEK liquid waste as F005 hazardous waste. The satellite container in which the spent
MEK is being accumulated must be kept securely closed at all times except when adding or removing
waste; the container must be labeled with the words "hazardous waste" and an indication of the hazards
of the contents. You may accumulate up to 55 gallons of hazardous waste in a satellite accumulation
area. Once you have reached 55 gallons, you must transfer the waste to a central accumulation area
within 3 days. The 90-day clock begins when you reach 55 gallons or when you move the container
from the area in which the waste is generated. Send me a photo of the closed and labeled satellite
accumulation container.
Train all employees (including Chad Kerr) who sign hazardous waste manifests on Department of
Transportation (DOT) Hazardous Material Shipping General Awareness, Function-Specific, Safety, and
Security (49 CFR 172.704).
Please provide records that document the training required in 49 CFR 172.704. Recordkeeping. Each
hazmat employer must create and retain a record of current training of each hazmat employee, inclusive
of the preceding three years for as long as that employee is employed by that employer as a hazmat
employee and for 90 days thereafter. The record must include: (1) The hazmat employee's name; (2)
The most recent training completion date of the hazmat employee's training; (3) A description, copy, or
the location of the training materials used to meet the requirements in paragraph (a) of this section; (4)
The name and address of the person providing the training; and (5) Certification that the hazmat
employee has been trained and tested.

Site: _________________________ EPA #: _______________ Date: __________
Hazardous Waste Inspection
Manifest Checklist
Inspectors Initials______
Requirements Manifests Reviewed
Manifest Number (box 4) # # # #
Generator EPA ID#
Appendix to R315-262 (box 1)
Generator information:
Mailing Address (box 5)
Phone Number
Transporter #1 information:
Company Name (box 6)
EPA ID# (box 6)
Transporter #2 information:
Company Name (box 7)
EPA ID# (box 7)
Designated Facility information:
Name and Address (box 8)
EPA ID# (box 8)
Phone Number (box 8)
Waste Shipping requirements:
DOT Description (Including proper
name, Hazard class, and ID #) (box 9b)
(box 9a "X" if hazardous materials)
Containers: No & Type (box 10)
Total Quantity (box 11)
Unit - Wt/Vol (box 12)
Waste Codes (box 13)
Special Handling Instructions
(box 14)
Manifest Certifications:
Generator's Signature (box15)
International Shipments (box 16)
Transporter's Signature (box 17 )
Discrepancy Indication (box 18)
Hazardous Waste Report Management
Method Codes (box 19)
Facility Signature (name of signer)
(box 20)
Shipped/Received Dates;
Observations; Comments for each
Manifest
Common container codes: DM - metal drum\barrel; DF - fiberbarrel; TT - cargo tank; TC - tank car; DT - dump truck; CM - metal
box\carton (includes roll-offs) Common Units of Measure: G - gallons; P - pounds; T - tons; Y - cubic yards)
4
Blanchard Metal Processing UTD009099987 4/30/2024
-
---
--
Yes
-
-
-
--
-
--
-
-
-
Yes ---
-
---
---
-
-
-
NA3077,
HAZARDOUS
WASTE, SOLID,
N.O.S. (CHROMIUM,
SILVER), 9, PG III
1CM 20Y (no
hazardous waste
code)
-
-
-
-
-
-
-
-
----
----
017112165FLE 017110780FLE
7/19/23-7/31/2
3
Rich Madsen
INSPECTION ITEM CITATION COMMENTS
Waste Determination:
1. Has the generator determined
whether his/her solid waste is a
hazardous waste?
2. Has a waste determination been done
for each waste stream?
R315-262
R315-262-11
40 CFR 262.11
R315-261-3
40 CFR 261.3
3. Has the generator notified of
regulated activity and obtained an
EPA ID# in accordance with the
requirements of Section 3010 of
RCRA?
R315-262-10(a)(1)(iii)(C)
40CFR262.10(a)(1)(iii)(C)
Manifest:
1. Is the generator using a Uniform
Hazardous Waste Manifest for its
shipments of hazardous waste?
2. Did the generator designate a facility
permitted to handle its waste?
3. Was an alternate facility designated?
4. Did the generator use the correct
manifest?
R315-262-20(a)(1)
R315-262-20(b)
R315-262-20(c)
Manifest requirements for the Generator:
1. Did the generator sign the manifest
certification by hand?
2. Did the generator obtain a handwritten
signature from the initial transporter and
the date of acceptance?
3. Did the generator retain a copy of the
manifest in accordance with
R315-262-40(a)?
R315-262-23(a)(1)
R315-262-23(a)(2)
R315-262-23(a)(3)
Recordkeeping:
1. Is the generator maintaining signed
copies of the hazardous waste manifest
for three years?
R315-262-40(a)
2. Is the generator maintaining copies
of each Biennial Report and all
Exception Reports for a period of at
least three years?
R315-262-40(b)
40 CFR 262.20(a)(1)
40 CFR 262.20(b)
R315-262-20(a)(1)
40 CFR 262.20(a)(1)
40 CFR 262.23(a)(1)
40 CFR 262.23(a)(2)
40 CFR 262.23(a)(3)
40 CFR 262.40(a)
40 CFR 262.40(b)
R315-262-18(a)
40 CFR 262.18(a)
Inspector's Initials
Large Quantity Generator Checklist
5
Blanchard Metal Processing UTD009099987 4/30/2024
Some manifests were signed by the
transporter on behalf of the generator. Rich
Madsen said the transporter called him when
that was necessary.
did not submit exception
report for one manifest
Yes
did not make a hazardous waste
determination on swabs and wipes used
to apply MEK and on spent liquid MEKNo
Yes
Yes
Yes
-
Yes
Yes
Yes
-
-
Yes
Yes
Yes
Yes
-
-
Yes
Site Name: EPA ID: Date:
Yes
Yes
INSPECTION ITEM CITATION COMMENTS
3.Is the facility maintaining records
sufficient to determine quantities and
disposition of hazardous waste or other
determinations, test results, or waste
analyses made in accordance with
R315-262-11(f) for a period of at least
three years from the date of last shipment?
R315-262-40(c)
Biennial Reporting
Has the generator submitted complete
Biennial Report(s)?
R315-262-41
40 CFR 262.41
Exception Reporting
Has the generator been required to
prepare an Exception Report, if yes
describe the circumstances?
R315-262-42
40 CFR 262.42
Packaging, Labeling, Marking, and
Placarding
1. Is the generator packaging his/her
hazardous waste in the appropriate
DOT shipping containers?
2. Are containers labeled and marked in
accordance with appropriate DOT
shipping requirements prior to shipping?
3.Is the generator providing or
offering appropriate placarding to
the initial transporter when
initiating his/her shipment?
R315-262-30
40 CFR 262.30
R315-262-31 &
R315-262-32
R315-262-33
40 CFR 262.33
Accumulation Times
(See Satellite, 90 Day and Tank
Checklists as applicable)
R315-262-17(a)
Also see checklists for:
Personnel Training,
Preparedness & Prevention,
Contingency Plan & Emergency
Procedures and Manifest
Comments:
40 CFR 262.40(c)
40 CFR 262.31 & 262.32
Inspector's Initials

Blanchard Metal Processing UTD009099987 4/30/2024
did not submit exception
report for manifest number
017110776FLE
Yes
Yes
Yes
Yes
-
-
Yes
Yes
Yes
Yes
Yes
-
-
Yes
Site Name: EPA ID: Date:
Site: _____________________ EPA #: _______________ Date: __________
Contingency Plan and Emergency Procedures Checklist
Inspectors Initials_______
INSPECTION ITEM CITATION COMMENTS
General Requirements:
Have copies been distributed to all local police and
fire departments, hospitals, and State and local
emergency response teams that may be called upon
for assistance?
R315-262-17(a)(6) (LQG)
R315-262-262(a) (LQG)
R315-261-420(c)(2) (HSM)
Content of the Contingency Plan:
1.Does the contingency plan describe the
actions facility personnel will take to minimize the
hazard to human health or the environment when
responding to fires, explosions, or any unplanned
sudden or non-sudden release of hazardous waste?
2.Does the contingency plan describe
arrangements agreed to by local police and fire
departments, hospitals, contractors, and State and
local emergency response teams?
3.Does the contingency plan list the names and
emergency telephone numbers of all persons
qualified to act as emergency coordinator?
4.Does the contingency plan include a list of all
emergency equipment at the facility? The list
must be kept up-to-date, and include the location
and a physical description of each item on the list,
and a brief outline of the equipment's capability.
5.Does the contingency plan include an
evacuation plan for the facility? This plan must
include a description of signal(s) to be used to
begin an evacuation, evacuation routes, and
alternate evacuation routes.
R315-262-261(a) (LQG)
R315-261-420(b)(1) (HSM)
R315-262-261(c) (LQG)
R315-261-420(b)(3) (HSM)
R315-262-261(d) (LQG)
R315-261-420(b)(4) (HSM)
R315-262-261(e) (LQG)
R315-261-420(b)(5) (HSM)
R315-262-261(f) (LQG)
R315-261-420(b)(6) (HSM)
If the facility first became subject to these
provisions after May 30, 2017, or has otherwise
amended its contingency plan, has it developed and
submitted a quick reference guide of the
contingency plan to local emergency responders in
R315-262-262(a), and state and local emergency
response teams that could be called for assistance?
R315-262-262(b) (LQG)
Not required - HSM
If the facility has a quick reference guide for its
contingency plan, does it have the following
required elements?:
1. Types/names of haz wastes and the associated
hazard for each haz waste present at any one time
(e.g., toxic paint wastes, spent ignitable solvent,
etc.)
2. Estimated maximum amount of each haz waste
that may be present at any one time
3. Identification of any haz wastes for which
exposure would require unique/special treatment by
medical or hospital staff
4. Map of the facility showing where haz wastes are
generated, accumulated and treated, and routes for
accessing these wastes
5. Street map of the facility in relation to
surrounding businesses, schools and residential areas
for the purpose of getting to it and/or evacuating
citizens and workers.
6. Locations of water supply (fire hydrant, flow rate)
7. Identified on-site notification systems (alarms)
8. Name of emergency coordinator and 24hr/7d/wk
emergency phone number
R315-262-262(b)(1) (LQG)
R315-262-262(b)(2) (LQG)
R315-262-262(b)(3) (LQG)
R315-262-262(b)(4) (LQG)
R315-262-262(b)(5) (LQG)
R315-262-262(b)(6) (LQG)
R315-262-262(b)(7) (LQG)
R315-262-262(b)(8) (LQG)
Note: this checklist is applicable to LQG's and to HSM handlers (except where indicated) who accumulate >6,000 kg (~13,228 lbs.)
This section not applicable for HSM handling
7
Blanchard Metal Processing UTD009099987 4/30/2024
Yes
Kerry Bertelsen has
retired but is still on CP
Yes
Yes
Yes
No
No
Yes
Kerry Bertelsen has retired but is still on QRG
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Site: _________________________ EPA #: _______________ Date: __________
Inspectors Initials_______
INSPECTION ITEM CITATION COMMENTS
Does the contingency plan outline the
procedure(s) that the emergency coordinator
will follow to immediately identify the
character, source, amount, and extent of
released material?
R315-262-265(b) (LQG)
R315-261-420(f)(2) (HSM)
Does the contingency plan include procedures
for the emergency coordinator to follow in
order to assess possible hazards to human
health or the environment?
R315-262-265(c) (LQG)
R315-261-420(f)(3) (HSM)
If it is determined that the incident could
threaten human health or the environment,
outside the facility, the emergency coordinator
must notify the appropriate local, State and
Federal agencies. Does the contingency plan
include provisions for notifying the
appropriate agencies? Do the notification
measures include information to be reported
(name and telephone # of reporter, name and
address of facility, name and quantity of
material(s) involved, extent of injuries, and
possibility of exposure outside the facility),
and identify the National Response Center
and the State as parties to be notified?
R315-262-265(d) (LQG)
R315-261-420(f)(4) (HSM)
Does the plan include procedures to prevent
the spread of the incident to other hazardous
waste/material at the facility?
R315-262-265(e) (LQG)
R315-261-420(f)(5) (HSM)
Are measures included to monitor for leaks,
pressure buildup, gas generation, or ruptures in
valves, pipes, or other equipment, when it is
necessary to shut-down operations as a
response to an incident?
R315-262-265(f) (LQG)
R315-261-420(f)(6) (HSM)
Does the contingency plan provide procedures to
follow to manage the hazardous waste/material
generated as a result of an incident?
R315-262-265(g) (LQG)
R315-261-420(f)(7) (HSM)
Following implementation of the contingency
plan, are provisions included to ensure that in
the affected area(s):
1. No waste that may be incompatible with the
released material is treated, stored, or disposed
of until the cleanup is complete.
2. That all equipment listed in the contingency
plan is cleaned and fit for use prior to
resuming activities at the facility.
R315-262-265(h)(1) (LQG)
R315-261-420(f)(8)(i) (HSM)
R315-262-265(h)(2) (LQG)
R315-261-420(f)(8)(ii) (HSM)
Does the facility have a least one employee
on-site or on-call at all time who is qualified to
act as the emergency coordinator?
Does the contingency plan include procedures
for activation of the internal alarm by the
emergency coordinator?
Does the contingency plan include provisions
for notifying the appropriate State and\or local
response agencies?
R315-262-264 (LQG)
R315-261-420(e) (HSM)
R315-262-265(a)(1) (LQG)
R315-261-420(f)(1)(i) (HSM)
R315-262-265(a)(2) (LQG)
R315-261-420(f)(1)(ii) (HSM)
Contingency Plan and Emergency Procedures Checklist
Note: this checklist is applicable to LQG's and to HSM handlers (except where indicated) who accumulate >6,000 kg (~13,228 lbs.)
8
Blanchard Metal Processing UTD009099987 4/30/2024

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Site: _________________________ EPA #: _______________ Date: __________
Contingency Plan and Emergency Procedures Checklist
Inspectors Initials_______
INSPECTION ITEM CITATION COMMENTS
The contingency plan must include
provisions for recording the incident
requiring implementation of the
contingency plan and specifying
information that will be recorded and
reported. The requirements are as follows:
1. Will a written report on the incident be
provided to the Utah State Department of
Environmental Quality within 15 days?
2. The following information needs to be
recorded and reported:
a) The name, address, and telephone # of the
owner/operator;
b) The name address, and telephone # of the
facility;
c) Date, time, and type of incident;
d) Name and quantity of material(s) involved;
e) Extent of injury, if any;
f) An assessment of the actual or potential
hazard to human health or the environment;
and
g) An estimate of the quantity and disposition
of recovered material(s) that resulted from the
incident.
R315-262-265(i) (LQG)
R315-261-420(f)(9) (HSM)
R315-262-265(i) (LQG)
R315-261-420(f)(9) (HSM)
R315-262-265(i)(1) thru (i)(7) (LQG)
R315-261-420(f)(9)(i) thru (f)(9)(vii) (HSM)
Note: this checklist is applicable to LQG's and to HSM handlers (except where indicated) who accumulate >6,000 kg (~13,228 lbs.)
HSM Only: Are all employees thoroughly
familiar with proper waste handling and
emergency procedures relevant to their
responsibilities during normal facility
operations and emergencies?
R315-261-420(g) (HSM)
9
Blanchard Metal Processing UTD009099987 4/30/2024

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
-
INSPECTION ITEM CITATION COMMENTS
Is the facility maintained and operated to
minimize the possibility of a fire, explosion, or
any unplanned sudden or non-sudden release
of hazardous waste or hazardous waste
constituents?
R315-262-251 (LQG)
R315-262-16(b)(8)(i) (SQG)
The facility must be equipped with items (1)-
(4), identified below, unless it can be shown
that hazardous waste managed at the site
would not require the particular kind of
equipment specified.
1. Does the facility have an internal
communications or alarm system capable of
providing immediate emergency instruction to
its personnel?
2. Does the facility have a device capable of
summoning external emergency assistance to
the facility (phone or two-way radio)?
3. Does the facility have portable
extinguishers, fire control equipment
(including special extinguishing equipment
necessary for their facility), spill control
equipment, and decontamination equipment?
4. Does the facility have water at adequate
volume and pressure to supply water hoses, or
foam producing equipment, or automatic
sprinklers, or water spray systems?
R315-262-252 (LQG)
Are facility communications or alarm systems,
fire protection equipment, spill control
equipment, and decontamination equipment
tested and maintained to assure its proper
operation in time of an emergency?
Do facility personnel have immediate access to
an internal alarm or emergency
communication device, either directly through
visual or voice contact, while managing
hazardous waste?
Is there ever just one employee on the
premises while the facility is operating? If
yes, does that person have immediate access to
device capable of summoning external
emergency assistance?
Site:EPA ID:Date
Inspector's Initials
R315-262-16(b)(8)(ii) (SQG)
Preparedness and Prevention Checklist
R315-261-410(a) (HSM)
R315-261-410(b) (HSM)
R315-262-252(a) (LQG)
R315-262-16(b)(8)(ii)(A) (SQG)
R315-261-410(b)(1) (HSM)
R315-262-252(b) (LQG)
R315-262-16(b)(8)(ii)(B) (SQG)
R315-261-410(b)(2) (HSM)
R315-262-252(c) (LQG)
R315-262-16(b)(8)(ii)(C) (SQG)
R315-261-410(b)(3) (HSM)
R315-262-252(d) (LQG)
R315-262-16(b)(8)(ii)(D) (SQG)
R315-261-410(b)(4) (HSM)
R315-262-253 (LQG)
R315-262-16(b)(8)(iii) (SQG)
R315-261-410(c) (HSM)
R315-262-254(a) (LQG)
R315-262-16(b)(8)(iv)(A) (SQG)
R315-261-410(d)(1) (HSM)
R315-262-254(b) (LQG)
R315-262-16(b)(8)(iv)(B) (SQG)
R315-261-410(d)(2) (HSM)
10
Blanchard Metal Processing UTD009099987 4/30/2024
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
INSPECTION ITEM CITATION COMMENTS
Is aisle space maintained to allow the
unobstructed movement of emergency
personnel or equipment (unless aisle space is
not needed for any of these purposes)?
The facility must arrange the following types
of agreements or arrangements with local
organizations (as appropriate):
1. Has the facility made or attempted to make
arrangements to familiarize local police, fire
departments, and emergency response teams
with the layout of the facility, character of the
hazardous waste(s) managed, locations where
facility personnel normally work, location of
facility entrances and possible evacuation
routes?
2. Has the facility designated primary
emergency authority to a specific police or fire
department, when more than one police or fire
department might respond in the event of an
emergency?
3. Have agreements with State emergency
response teams, emergency responses
contractors, and equipment suppliers been
made?
4. Have arrangements been made to
familiarize local hospitals with the properties
of hazardous waste handled at the facility and
the types of injuries or illnesses which could
result from fires, explosions, or releases at the
facility?
If any State or local authorities have declined
to enter into such arrangements, has the
facility documented the refusal in the
operating record?
Site:EPA ID:Date
Inspector's Initials
Preparedness and Prevention Checklist
R315-262-255 (LQG)
R315-262-16(b)(8)(v) (SQG)
R315-261-410(e) (HSM)
R315-262-256(a) (LQG)
R315-262-16(b)(8)(vi)(A) (SQG)
R315-261-410(f)(1) (HSM)
R315-262-256(a)(2) (LQG)
R315-262-16(b)(8)(vi)(A)(II) (SQG)
R315-261-410(f)(1)(i) (HSM)
R315-262-256(a)(3) (LQG)
R315-262-16(b)(8)(vi)(A)(III) (SQG)
R315-261-410(f)(1)(ii) (HSM)
R315-262-256(a)(1) (LQG)
R315-262-16(b)(8)(vi)(A)(I) (SQG)
R315-261-410(f)(1)(iii) (HSM)
R315-262-256(a)(2) (LQG)
R315-262-16(b)(8)(vi)(A)(II) (SQG)
R315-261-410(f)(1)(iv) (HSM)
R315-262-256(b) (LQG)
R315-262-16(b)(8)(vi)(B) (SQG)
R315-261-410(f)(2) (HSM)
11
Blanchard Metal Processing UTD009099987 4/30/2024
NA
Yes
Yes
No
NA
AET will provide
contracted response
supportNo
Yes
-
Site: _________________________ EPA #: _______________ Date: __________
Hazardous Waste Inspection
Personnel Training Checklist
Inspectors Initials______
INSPECTION ITEM CITATION COMMENTS
Facility personnel must successfully complete
classroom instruction, online training or on-
the-job training which teaches them to
perform their jobs, such that the facility is
operated in compliance with the applicable
hazardous waste management requirements.
R315-262-17(a)(7)(i)(B)
40CFR262.17(a)(7)(i)(B)Is the program directed by a person trained in
hazardous waste management procedures?
Does the training teach facility personnel
hazardous waste management and contingency
plan implementation procedures?
Does the training program include, at a
minimum, the following, where applicable:
1. Procedures for using, inspecting, repairing,
and replacing facility emergency equipment;
2. Key parameters for automatic waste cut-off
systems;
3. Communications or alarm systems;
4. Response to fires or explosions;
5. Response to groundwater
contamination incidents;
6. Shutdown of operations; and
Have facility personnel successfully completed
the personnel training program within six
months of the date of their employment or
assignment to the facility?
Do the facility personnel receive an annual
review of their initial training?
R315-262-17(a)(7)(i)(A)
40CFR262.17(a)(7)(i)(A)
R315-262-17(a)(7)(i)(B)
40CFR262.17(a)(7)(i)(B)
R315-262-17(a)(7)(i)(C)
40CFR262.17(a)(7)(i)(C)
R315-262-17(a)(7)(i)(C)(1)
40CFR262.17(a)(7)(i)(C)(1)
R315-262-17(a)(7)(i)(C)(2)
40CFR262.17(a)(7)(i)(C)(2)
R315-262-17(a)(7)(i)(C)(3)
40CFR262.17(a)(7)(i)(C)(3)
R315-262-17(a)(7)(i)(C)(4)
40CFR262.17(a)(7)(i)(C)(4)
R315-262-17(a)(7)(i)(C)(5)
40CFR262.17(a)(7)(i)(C)(5)
R315-262-17(a)(7)(i)(C)(6)
40CFR262.17(a)(7)(i)(C)(6)
R315-262-17(a)(7)(ii)
40CFR262.17(a)(7)(ii)
R315-262-17(a)(7)(iii)
40CFR262.17(a)(7)(iii)
12
Blanchard Metal Processing UTD009099987 4/30/2024
Rich Madsen and Chad Kerr signed
manifests. Chad Kerr has not had DOT
training. No documentation of DOT
training for Rich, but he says he has
had it. Sent Rich excerpt of the DOT
training documentation requirements.
see comment above about
Chad Kerr
Yes
Yes
Yes
Yes
N/A
Yes
Yes
N/A
Yes
Yes
Yes
Site: _________________________ EPA #: _______________ Date: __________
Hazardous Waste Inspection
Personnel Training Checklist
Inspectors Initials______
INSPECTION ITEM CITATION COMMENTS
The owner/operator of the facility must
maintain the following documents at the
facility:
1. The job title for each position at the facility
related to hazardous waste management, and
the name of the employee filling each job;
2. A written job description for each position
listed under #1;
3. A written description of the type and
amount of both introductory and continuing
training that will be given to the employees
listed in #1, and;
4. Records that document that employees have
the training or job experience required by
paragraphs 265.16 (a), (b), and (c).
Are training records maintained at the facility
for current employees and for at least three
years for employees that have left the
company?
R315-262-17(a)(7)(iv)
40CFR262.17(a)(7)(iv)
R315-262-17(a)(7)(v)
40CFR262.17(a)(7)(v)
R315-262-17(a)(7)(iv)(A)
40CFR262.17(a)(7)(iv)(A)
R315-262-17(a)(7)(iv)(B)
40CFR262.17(a)(7)(iv)(B)
R315-262-17(a)(7)(iv)(C)
40CFR262.17(a)(7)(iv)(C)
R315-262-17(a)(7)(iv)(D)
40CFR262.17(a)(7)(iv)(D)
13
Blanchard Metal Processing UTD009099987 4/30/2024
Yes
Yes
Yes
Yes
but doesn't include DOT training in the
description, but RMEC provides
(according to Rich Madsen)
Yes
Site: ______________________ EPA #: _______________ Date: __________
Hazardous Waste Inspection
90 Day Storage Site
>55 gallons
Inspectors Initials_______
INSPECTION ITEM CITATION COMMENTS
1. Is the container labeled with the
words "Hazardous Waste"?
3.Is the date upon which accumulation
began clearly marked and visibly for
inspection?
4.Is that date <= 90 days old?
R315-262-17(a)(5)(i)(A)
4. Is there a Preparedness and Prevention
Plan for this site or the facility as a whole,
including this site? (see separate Check List)
5.Operated to minimize chance of Spill or Fire?
6.Spill and Fire control equipment?
7.Emergency communication device: Internal?
Emergency communication device: External?
Sufficient Aisle and Access space?
R315-262-251
R315-262-252(c)
R315-262-252(a)
R315-262-252(b)
R315-262-255
8. Is there a Contingency Plan for this site or
the facility as a whole, including this site?
(see separate Check List)
9.a. Description of actions that should be taken?
b.Name & Phone # for Emergency Coordinator?
c. Primary and alternate evacuation routes?
d.List of emergency equipment & location?
R315-262-17(a)(6)
R315-262-261(a)
R315-262-261(d)
R315-262-261(f)
R315-262-261(e)
Have personnel at this site Successfully
completed up to date Personnel Training on
HzW Handling & Fire & Spill Response?
Is the training documented?
(see separate Check List)
R315-262-17(a)(7)(i)
R315-262-17(a)(7)(v)
Are the containers accumulating and holding
hazardous waste in good condition?
Are they compatible with the HzW in them?
R315-262-17(a)(1)(ii)
R315-262-17(a)(1)(iii)
Is the generator maintaining his/her containers
in a closed condition except when adding or
removing waste from the container?
R315-262-17(a)(1)(iv)(A)
Are containers holding hazardous waste
opened, handled or stored in a manner
which could cause them to leak?
Is the generator inspecting his/her containers
at least weekly for leaks, deterioration, and
any factor that may cause a release of
hazardous waste?
R315-262-17(a)(1)(v)
Is ignitable or reactive hazardous waste stored
within 50 feet of the facility's property line?
2.Is the container marked or labeled
with an indication of the hazards of
the contents?
R315-262-17(a)(5)(i)(B)
R315-262-17(a)(5)(i)(C)
R315-262-17(a)
R315-262-17(a)(6)
R315-262-250 thru 256
R315-262-260 thru 265
R315-262-17(a)(1)(iv)(B)
R315-262-17(a)(1)(vi)(A)
14
Blanchard Metal Processing UTD009099987 4/30/2024
1 - roll-off labeled HW
2 - RM added "toxic" to roll-off
3 - yes
4 - yes
yes
yes
yes
yes
yes
yes
N
Y
N
Site: _________________________ EPA #: _______________ Date: __________
Hazardous Waste Inspection
Satellite Accumulation Checklist
<55 gallons
Inspectors Initials______
INSPECTION ITEM CITATION COMMENTS
Is the satellite accumulation area at or near the
point of generation?
R315-262-15(a)
Is the satellite area under the control of the
operator of the process generating the waste? R315-262-15(a)
Does the generator have the accumulation
container labeled with the words "hazardous
waste"?R315-262-15(a)(5)(i)
Can the generator store more than 55 gallons of
hazardous waste or 1 quart of acutely hazardous
waste at the satellite accumulation area? Note
how much is stored in the comment box. R315-262-15(a)
Are containers in good condition, and
managed so they do not leak or spill? R315-262-15(a)(1)
Is the hazardous waste stored in containers that
are compatible with the waste? R315-262-15(a)(2)
Is the accumulation container being
maintained in a closed condition except
when waste is being added or removed, or
when temporary venting is necessary for
proper operation of equipment or to prevent
dangerous situations such as pressure
buildup?
R315-262-15(a)(4)
Does the generator have the accumulation
containers marked with an indication of the
hazards of its contents?
R315-262-15(a)(5)(ii)
Is hazardous waste in excess of the 55 gal or
1 qt limits, labeled & moved to a central
accumulation area within 72 hours? R315-262-15(a)(6 )(i)
15
Blanchard Metal Processing UTD009099987 4/30/2024
yes
Y
N
N
Y
Y
N
N
-
Hazardous Waste Inspection
Universal Waste
Small Quantity Handler (less than 5,000 kg)
INSPECTION ITEM REGULATORY CITATION COMMENTS
Does the facility manage any of the
following universal waste streams:
1.Batteries?
2. Pesticides?
3.Mercury Containing Equipment?
4a. Lamps?
7.Household and Conditionally Exempt
Small Quantity Generator Waste?
R315-273-2 and R315-273-13(a)
R315-273-3 and R315-273-13(b)
R315-273-4 and R315-273-13(c)
R315-273-5, R315-273-13(d) & (d)(3)
R315-273-8
Did the handler dispose of, dilute or treat
any waste?
Are waste batteries managed to prevent
releases?
Are waste batteries that are leaking,
spilling or damaged placed in a container?
R315-273-13(a)
R315-273-13(a)(1)
Has the handler determined if any
electrolyte or other solid waste removed
from waste batteries exhibits a
characteristic of hazardous waste?
Is the electrolyte or other solid waste
being managed properly?
R315-273-13(a)(3)
R315-273-13(a)(3)(i) and (ii)
Are waste pesticides managed to prevent
releases by being properly containerized? R315-273-13(b)
Is waste mercury containing equipment
managed to prevent releases by being
properly containerized?
R315-273-13(c)(1)
Does the handler properly remove and
manage mercury containing ampules? R315-273-13(c)(2)(i) – (ii)
Does the handler have equipment, systems
and procedures in place for handling spills
or leaks of mercury?
Are employees who remove ampules
properly trained in mercury handling and
emergency procedures?
R315-273-13(c)(2)(iii) – (v)
R315-273-13(c)(2)(vi)
Does the handler properly pack and store
removed ampules? R315-273-13(c)(2)(vii) – (viii)
Does the handler properly manage waste
mercury-containing equipment that does
not contain an ampule? R315-273-13(c)(3)
Has the handler determined if any
mercury, clean-up residues or other solid
waste generated from removal of mercury
containing ampules exhibits a
characteristic of hazardous waste?
Is the waste being managed properly?
R315-273-13(c)(4)
R315-273-13(c)(4)(ii) – (iii)
4b. Drum-Top Crusher?
5. Antifreeze?
6. Aerosol Cans?
R315-273-6(a) and R315-273-13(e)
R315-273-6(b) and R315-273-13(f)
R315-273-11
Inspector's Initials
Are waste lamps managed to prevent
releases by being properly containerized? R315-273-13(d)
If the handler performs crushing of
universal waste lamps, is it properly
managing the drum-top crusher?
Did the handler apply and receive
approval for the drum-top crusher?
R315-273-13(d)(3)
Site:EPA ID:Date:
January 2018 16
Blanchard Metal Processing UTD009099987 4/30/2024
INSPECTION ITEM REGULATORY CITATION COMMENTS
Are waste batteries or containers labeled
“Universal Waste Battery” or “Waste
Batteries” or "Used Batteries"?
R315-273-14(a)
Are containers, tanks or vessels of recalled
waste pesticides labeled with the label that
was on or accompanied the product and
“Universal Waste Pesticide” or “Waste
Pesticides”?
R315-273-14(b)
Are containers, tanks or vessels of unused
pesticide products labeled with the label
that was on the product or required DOT
label or label prescribed by a waste
pesticide collection program and
“Universal Waste Pesticide” or “Universal
Waste Pesticides”?
R315-273-14(c)(1) – (2)
Are waste mercury containing devices or
containers labeled, “Universal Waste
Mercury Containing Equipment”, Waste
Mercury Containing Equipment” or “Used
Mercury Containing Equipment”?
R315-273-14(d)(1)
Are waste mercury containing thermostats
or containers labeled, “Universal Waste
Mercury Thermostat(s)”, “Waste Mercury
Thermostat(s)” or “Used Mercury
Thermostat(s)”?
R315-273-14(d)(2)
Are each waste lamp, container or package
labeled, “Universal Waste Lamp(s)”,
Waste Lamp(s)” or “Used Lamp(s)”?
R315-273-14(e)
Can the handler demonstrate the length of
time the waste has been accumulated?
Is the period longer than one year?
If longer than one year can the handler
prove that the purpose is to accumulate
quantities as necessary to facilitate proper
recovery, treatment or disposal?
R315-273-15(c)
R315-273-15(a)
R315-273-15(b)
Has the handler provided employees who
handle or manage universal waste with
proper handling and emergency response
procedures?
R315-273-16
Has the handler properly contained and
managed all releases of waste and residues
from waste?
R315-273-17
Did the handler send universal waste to any
facility other than a universal waste
handler, destination facility or foreign
destination?
Did the handler transport the waste? If so,
see check list for Universal Waste
Transporters.
Did the handler properly package, label,
mark and placard the waste and prepare
proper shipping documents?
R315-273-18(a)
R315-273-18(b)
R315-273-18(c)
Did the handler have any shipments of
waste rejected by receiving facilities?
Did the handler reject any shipments of
waste?
R315-273-18(e)
R315-273-18(f)
R315-273-14(f) Are waste antifreeze containers, tanks or
transport vessels labeled, “Universal Waste
Antifreeze” or Waste Antifreeze”?
Are waste aerosol cans or containers of
cans labeled, “Universal Waste Aerosol
Can(s)" or "Waste Aerosol Can(s)"?
R315-273-14(g)
Did the handler receive any shipments that
contained hazardous waste? If so, was the
Director immediately notified?
R315-273-18(g)
Did the handler export any waste? R315-273-20
Site:EPA ID:Date:
Inspector's Initials
January 2018 17
Blanchard Metal Processing UTD009099987 4/30/2024
Judith Moran <[e-mail]>
Follow-up from Blanchard Metals Processing inspection
1 message
Judith Moran <[e-mail]>Wed, May 1, 2024 at 5:51 PM
To: rich <[e-mail]>
Cc: Sally Kaiser <[e-mail]>
Hi Rich,
Thank you for showing us around Blanchard and for being so engaged about compliance with the RCRA regulations. Attached are excerpts from
the rules about exception reporting and about exempt solvent-contaminated wipes.
Here are the items that require some follow-up:
1. Yesterday we found one manifest that required an exception report, 017110776FLE. Please reach out to your transporter and ask them
why they transferred the waste from manifest number 017109304FLE to manifest #017110776FLE and where the waste was stored
between the time it was picked up on 1/6/23 and when Ana Lopez, US Ecology in Beatty NV signed manifest #017110776FLE on
7/31/23. Neither manifest is in EPA's electronic manifest system so it is important to learn where the waste was over those 7 months, and
to verify that it was actually received at US Ecology in Beatty NV.
2. Update Blanchard's contingency plan with the list of emergency equipment, where the equipment is located, an evacuation plan, and
remove Kerry Bertelsen. Send the updated plan to your local responders and copy me on the email so I know you've sent it to them.
3. Label the tote and 4 drums with the words "used oil" and send me a photo.
4. Clean up the very small amount of filter cake on the floor underneath the filter press and send me a photo.
5. Manage rags and swabs used to apply MEK as either F005 hazardous waste or as exempt wipes that are disposed of (see attached
regulatory excerpt) Let me know which option you have chosen and then send me photos of the swab and rag containers.
6. Manage spent MEK liquid waste as F005 hazardous waste. The satellite container in which the spent MEK is being accumulated must be
kept securely closed at all times except when adding or removing waste; the container must be labeled with the words "hazardous waste"
and an indication of the hazards of the contents. You may accumulate up to 55 gallons of hazardous waste in a satellite accumulation
area. Once you have reached 55 gallons, you must transfer the waste to a central accumulation area within 3 days. The 90-day clock
begins when you reach 55 gallons or when you move the container from the area in which the waste is generated. Send me a photo of
the closed and labeled satellite accumulation container.
7. Train all employees (including Chad Kerr) who sign hazardous waste manifests on Department of Transportation (DOT) Hazardous
Material Shipping General Awareness, Function-Specific, Safety, and Security (49 CFR 172.704).
8. Please provide records that document the training required in 49 CFR 172.704. Recordkeeping. Each hazmat employer must create and
retain a record of current training of each hazmat employee, inclusive of the preceding three years for as long as that employee is
employed by that employer as a hazmat employee and for 90 days thereafter. The record must include: (1) The hazmat employee's
name; (2) The most recent training completion date of the hazmat employee's training; (3) A description, copy, or the location of the
training materials used to meet the requirements in paragraph (a) of this section; (4) The name and address of the person providing the
training; and (5) Certification that the hazmat employee has been trained and tested.
Please email or call me if you have any questions.
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and Radiation Control, P.O. Box 144880,
Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
2 attachments
Solvent wipes exclusion R315-261-4.docx
14K
Manifest exception reporting.docx
15K
Judith Moran <[e-mail]>
Invitation: Blanchard Metals Processing Co UTD009099987 CEI @ Tue Apr 30, 2024 12:30pm -
4:30pm (MDT) ([e-mail])
1 message
Judith Moran <[e-mail]>Wed, Apr 17, 2024 at 9:06 AM
Reply-To: Judith Moran <[e-mail]>
To: [e-mail], Sally Kaiser <[e-mail]>

When
Tuesday Apr 30, 2024 ⋅ 12:30pm – 4:30pm (Mountain Time - Denver)
Guests
Judith Moran - organizer
Sally Kaiser
[e-mail]
View all guest info
Reply for [e-mail]
Yes No Maybe More options
Invitation from Google Calendar
You are receiving this email because you are an attendee on the event. To stop receiving future updates for this event, decline this event.
Forwarding this invitation could allow any recipient to send a response to the organizer, be added to the guest list, invite others regardless of their own
invitation status, or modify your RSVP. Learn more
invite.ics
2K
Judith Moran <[e-mail]>
LHD Notification - Blanchard Metals Processing Co. UTD009099987 CEI
1 message
Judith Moran <[e-mail]>Sun, Apr 28, 2024 at 10:10 PM
To: Hayley Shaffer <[e-mail]>
Hi Hayley,
I will be inspecting Blanchard Metals Processing Company on Tuesday. I sent you a meeting invitation in case you or someone from your staff
would like to participate.
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and Radiation Control, P.O. Box 144880,
Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
Judith Moran <[e-mail]>
Re: Fwd: Hazardous waste inspection
1 message
Judith Moran <[e-mail]>Wed, Apr 17, 2024 at 9:20 AM
To: rich <[e-mail]>
Cc: Sally Kaiser <[e-mail]>
Hi Rich, I sent you the meeting invitation. See you on the 30th. Attached is the inspection checklist we will use. Please feel free to reach out if
you have any questions before the inspection.
On Wed, Apr 17, 2024 at 8:28 AM rich <[e-mail]> wrote:
Thanks ... please let me know.
--
Rich Madsen
Quality Manager
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is not the intended
recipient, or an employee or
agent responsible for delivering this message to the intended recipient, you are hereby notified that any reliance upon,
dissemination,
distribution or copying of this communication, or the information contained in it, is strictly prohibited. If you have
received this
communication in error, please notify us immediately by replying to the message and deleting it from your computer.
This document may contain technical data within the definition of the International Traffic in Arms Regulations ITAR (22
CFR 120)
and is subject to the export controls laws of the U.S. Government. Transfer of this data by any means to a foreign
person or foreign entity,
whether in the United States or abroad, without an export license, ITAR exemption or other approval from the U.S.
Department of State and
Blanchard Metals Processing is strictly prohibited. Any/All Prints or technical data are to be destroyed, deleted, or
returned to Blanchard Metals.
On 4/16/2024 6:25 PM, Judith Moran wrote:
yes, I can do the 30th. Maybe in the afternoon instead? I need to check with my co-inspector.
On Tue, Apr 16, 2024 at 6:07 PM rich <[e-mail]> wrote:
Judy,
Steve forwarded this to me and I need to ask if I can do it the following week, as I won't be in that day.
Will the 30th work for you? Please let me know.
Thanks,
--
Rich Madsen
Quality Manager
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is not the
intended recipient, or an employee or
agent responsible for delivering this message to the intended recipient, you are hereby notified that any
reliance upon, dissemination,
distribution or copying of this communication, or the information contained in it, is strictly prohibited.
If you have received this
communication in error, please notify us immediately by replying to the message and deleting it from your
computer.
This document may contain technical data within the definition of the International Traffic in Arms
Regulations ITAR (22 CFR 120)
and is subject to the export controls laws of the U.S. Government. Transfer of this data by any means to a
foreign person or foreign entity,
whether in the United States or abroad, without an export license, ITAR exemption or other approval from the
U.S. Department of State and
Blanchard Metals Processing is strictly prohibited. Any/All Prints or technical data are to be destroyed,
deleted, or returned to Blanchard Metals.
On 4/15/2024 5:19 PM, Steve wrote:
FYI
Thank You,
Steven Rij
President
MAILING ADDRESS
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
SHIPPING ADDRESS
1115 So.Pioneer Road
Salt Lake City, Utah 84104
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is
not the intended recipient, or an employee or agent responsible for delivering this message to
the intended recipient, you are hereby notified that any reliance upon, dissemination,
distribution or copying of this communication, or the information contained in it, is strictly
prohibited. If you have received this communication in error, please notify us immediately by
replying to the message and deleting it from your computer. Thank you. Blanchard Metals
Processing Company.
-------- Forwarded Message --------
Subject:Hazardous waste inspection
Date:Mon, 15 Apr 2024 13:11:12 -0600
From:Judith Moran <[e-mail]>
To:[e-mail]
Hello Steve,
I am a hazardous waste inspection with the Utah Department of Environmental Quality and I am reaching out to
you to set up a hazardous waste inspection at your facility on April 23, 2024. It seems that Rich Madsen is
probably the person I will need to interact with, however our records do not include his contact information.
I would greatly appreciate you passing this on to him to make the necessary arrangements to confirm my visit.
Thank you,
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and
Radiation Control. If you desire a statement of the Division Director’s position, please submit a written request to Director,
Division of Waste Management and Radiation Control, P.O. Box 144880, Salt Lake City, Utah 84114-4880, including copies of
documents relevant to your request.
--
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control.
If you desire a statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and
Radiation Control, P.O. Box 144880, Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
--
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and Radiation Control, P.O. Box 144880,
Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
Blanchard Metals Processing Inspection Checklist 4.30.24.pdf
1340K
Judith Moran <[e-mail]>
Re: Fwd: Hazardous waste inspection
1 message
Judith Moran <[e-mail]>Tue, Apr 16, 2024 at 6:25 PM
To: rich <[e-mail]>
yes, I can do the 30th. Maybe in the afternoon instead? I need to check with my co-inspector.
On Tue, Apr 16, 2024 at 6:07 PM rich <[e-mail]> wrote:
Judy,
Steve forwarded this to me and I need to ask if I can do it the following week, as I won't be in that day.
Will the 30th work for you? Please let me know.
Thanks,
--
Rich Madsen
Quality Manager
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is not the intended
recipient, or an employee or
agent responsible for delivering this message to the intended recipient, you are hereby notified that any reliance upon,
dissemination,
distribution or copying of this communication, or the information contained in it, is strictly prohibited. If you have
received this
communication in error, please notify us immediately by replying to the message and deleting it from your computer.
This document may contain technical data within the definition of the International Traffic in Arms Regulations ITAR (22
CFR 120)
and is subject to the export controls laws of the U.S. Government. Transfer of this data by any means to a foreign
person or foreign entity,
whether in the United States or abroad, without an export license, ITAR exemption or other approval from the U.S.
Department of State and
Blanchard Metals Processing is strictly prohibited. Any/All Prints or technical data are to be destroyed, deleted, or
returned to Blanchard Metals.
On 4/15/2024 5:19 PM, Steve wrote:
FYI
Thank You,
Steven Rij
President
MAILING ADDRESS
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
SHIPPING ADDRESS
1115 So.Pioneer Road
Salt Lake City, Utah 84104
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is not the
intended recipient, or an employee or agent responsible for delivering this message to the intended recipient,
you are hereby notified that any reliance upon, dissemination, distribution or copying of this communication,
or the information contained in it, is strictly prohibited. If you have received this communication in error,
please notify us immediately by replying to the message and deleting it from your computer. Thank you.
Blanchard Metals Processing Company.
-------- Forwarded Message --------
Subject:Hazardous waste inspection
Date:Mon, 15 Apr 2024 13:11:12 -0600
From:Judith Moran <[e-mail]>
To:[e-mail]
Hello Steve,
I am a hazardous waste inspection with the Utah Department of Environmental Quality and I am reaching out to you to set up a
hazardous waste inspection at your facility on April 23, 2024. It seems that Rich Madsen is probably the person I will need to
interact with, however our records do not include his contact information.
I would greatly appreciate you passing this on to him to make the necessary arrangements to confirm my visit.
Thank you,
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control.
If you desire a statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and
Radiation Control, P.O. Box 144880, Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
--
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to Director, Division of Waste Management and Radiation Control, P.O. Box 144880,
Salt Lake City, Utah 84114-4880, including copies of documents relevant to your request.
Deq submit <[e-mail]>
Re: Follow-up from Blanchard Metals Processing inspection
1 message
rich <[e-mail]>Thu, Jun 27, 2024 at 4:14 PM
To: [e-mail]
Cc: Rich <[e-mail]>
Hi Judy,
Thanks for your patience as I have worked through getting this information prepared for you. Please see below for a
summary of actions taken and advise if you require anything else:
1. I reached out to Gary Mossor, the Head of Operations, at AET who informed me that the waste on manifest
017109304FLE, when initially picked up at Blanchard, was planned on being treated at Clean Harbors in Aragonite
Utah. However, on February 21st, Clean Harbors notified them there was a hold on their shipping incinerator and
would not be able to pick it up. He explained that AET then kept the 3 drums on their transporter and it moved
between the Salt Lake, Denver & Las Vegas locations, as to not violate the 10 day holding requirement, until US
Ecology agreed to accept the material July 11, at which time it was transferred to 017110776FLE. If you have any
additional questions, he was more than happy to speak with you.
2. BMT 500 (Emergency Contingency Plan) updated to revision F to address:
1. List of emergency equipment (section 3.0 & 4.0)
2. Plant layout updated to revision I showing the location of spill kits (other equipment was previously and still
is identified).
3. Detailed evacuation plan, based on each employee's assigned number, in section 16.0.
4. Kerry Bertelsen removed from procedure
3. 4 drums of oil were re-labeled with USED OIL rather than WASTE OIL
4. Small amount of filter cake was removed
5. Rags are not used with MEK, however cotton swabs are. 4 "Justrite" containers were purchased, labeled and put
at the point of use. Emergency Contingency Plan updated in section 18 #4.
6. Flammable cabinet purchased, labeled, and 55 Gallon drum placed inside for "satellite" collection. Section 18 #4
again describes this in the Emergency Contingency Plan.
7. Rich Madsen, Steve Rij and Chad Kerr trained to D.O.T. Hazardous Material Shipping General Awareness
requirements. Details of this training covered in section 7.
8. All Blanchard Key Personnel identified in procedure BMT 500-1 were given annual hazardous waste training using
the same training outline shown when you were on site.
Please let me know if you have any questions.
Thanks,
Rich Madsen
Quality Manager
Blanchard Metals Processing Co.
P.O. Box 26695
Salt Lake City, Utah 84126-0695
PH: 801-972-5590
FX: 801-972-6346
Website: www.bmproc.com
The information contained in this message may be confidential. If the reader of this message is not the
intended recipient, or an employee or
agent responsible for delivering this message to the intended recipient, you are hereby notified that any
reliance upon, dissemination,
distribution or copying of this communication, or the information contained in it, is strictly prohibited.
If you have received this
communication in error, please notify us immediately by replying to the message and deleting it from your
computer.
6/28/24, 1:25 PM State of Utah Mail - Re: Follow-up from Blanchard Metals Processing inspection
https://mail.google.com/mail/b/AEoRXRRnJTOXdjEl4uZwM74rW5jqVIETb81UZoAxnylIi1TvI7F3/u/0/?ik=adf9d5e615&view=pt&search=all&permthid=t…1/3
http://
www.bmproc.
com/
This document may contain technical data within the definition of the International Traffic in Arms
Regulations ITAR (22 CFR 120)
and is subject to the export controls laws of the U.S. Government. Transfer of this data by any means to
a foreign person or foreign entity,
whether in the United States or abroad, without an export license, ITAR exemption or other approval from
the U.S. Department of State and
Blanchard Metals Processing is strictly prohibited. Any/All Prints or technical data are to be destroyed,
deleted, or returned to Blanchard Metals.
On 5/1/2024 5:51 PM, Judith Moran wrote:
Hi Rich,
Thank you for showing us around Blanchard and for being so engaged about compliance with the RCRA
regulations. Attached are excerpts from the rules about exception reporting and about exempt solvent-
contaminated wipes.
Here are the items that require some follow-up:
1. Yesterday we found one manifest that required an exception report, 017110776FLE. Please reach
out to your transporter and ask them why they transferred the waste from manifest number
017109304FLE to manifest #017110776FLE and where the waste was stored between the time it
was picked up on 1/6/23 and when Ana Lopez, US Ecology in Beatty NV signed manifest
017110776FLE on 7/31/23. Neither manifest is in EPA's electronic manifest system so it is
important to learn where the waste was over those 7 months, and to verify that it was actually
received at US Ecology in Beatty NV.
2. Update Blanchard's contingency plan with the list of emergency equipment, where the equipment is
located, an evacuation plan, and remove Kerry Bertelsen. Send the updated plan to your local
responders and copy me on the email so I know you've sent it to them.
3. Label the tote and 4 drums with the words "used oil" and send me a photo.
4. Clean up the very small amount of filter cake on the floor underneath the filter press and send me a
photo.
5. Manage rags and swabs used to apply MEK as either F005 hazardous waste or as exempt wipes
that are disposed of (see attached regulatory excerpt) Let me know which option you have chosen
and then send me photos of the swab and rag containers.
6. Manage spent MEK liquid waste as F005 hazardous waste. The satellite container in which the spent
MEK is being accumulated must be kept securely closed at all times except when adding or
removing waste; the container must be labeled with the words "hazardous waste" and an indication
of the hazards of the contents. You may accumulate up to 55 gallons of hazardous waste in a
satellite accumulation area. Once you have reached 55 gallons, you must transfer the waste to a
central accumulation area within 3 days. The 90-day clock begins when you reach 55 gallons or
when you move the container from the area in which the waste is generated. Send me a photo of the
closed and labeled satellite accumulation container.
7. Train all employees (including Chad Kerr) who sign hazardous waste manifests on Department of
Transportation (DOT) Hazardous Material Shipping General Awareness, Function-Specific, Safety,
and Security (49 CFR 172.704).
8. Please provide records that document the training required in 49 CFR 172.704. Recordkeeping.
Each hazmat employer must create and retain a record of current training of each hazmat employee,
inclusive of the preceding three years for as long as that employee is employed by that employer as
a hazmat employee and for 90 days thereafter. The record must include: (1) The hazmat employee's
name; (2) The most recent training completion date of the hazmat employee's training; (3) A
description, copy, or the location of the training materials used to meet the requirements in paragraph
a) of this section; (4) The name and address of the person providing the training; and (5)
Certification that the hazmat employee has been trained and tested.
Please email or call me if you have any questions.
Judy Moran | Environmental Scientist | Hazardous Waste Programs
1 [phone] (direct/mobile) | 801 536-0200 (front desk) | 801 536-0222 ( fax)
195 North 1950 West, Salt Lake City, Utah 84116
6/28/24, 1:25 PM State of Utah Mail - Re: Follow-up from Blanchard Metals Processing inspection
https://mail.google.com/mail/b/AEoRXRRnJTOXdjEl4uZwM74rW5jqVIETb81UZoAxnylIi1TvI7F3/u/0/?ik=adf9d5e615&view=pt&search=all&permthid=t…2/3
https://www.google.com/maps/
search/1950+West,+Salt+Lake
+City,+Utah+%C2%A084116?
entry=gmail&source=g
Statements made in this email do not constitute the official position of the Director of the Division of Waste Management
and Radiation Control. If you desire a statement of the Division Director’s position, please submit a written request to
Director, Division of Waste Management and Radiation Control, P.O. Box 144880, Salt Lake City, Utah 84114-4880,
including copies of documents relevant to your request.
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237K
6/28/24, 1:25 PM State of Utah Mail - Re: Follow-up from Blanchard Metals Processing inspection
https://mail.google.com/mail/b/AEoRXRRnJTOXdjEl4uZwM74rW5jqVIETb81UZoAxnylIi1TvI7F3/u/0/?ik=adf9d5e615&view=pt&search=all&permthid=t…3/3
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BMT 500 Rev. F 06-12-2024 1
BLANCHARD METALS PROCESSING CO.
1115 SO. PIONEER ROAD
SALT LAKE CITY, UT. 84104
EMERGENCY CONTINGENCY PLAN
APPROVED FOR THE COMPANY:
MANAGEMENT: ______________________
QUALITY: ______________________
BLANCHARD METALS PROCESSING CO.
A Utah Corporation
BMT 500 Rev. F 06-12-2024 2
Revisions:
A: 1/15/2004 Revised to add Nadcap requirements, and to revise to new
Numbering system “BMT”
B: 1/13/2006 Revised 2.0 Notification List to update phone list.
Made an addition to the Specified Personnel. (6.0)
C: 4/30/2007 Reviewed and updated the list of employees for chemical
Additions.
D: 01/19/2016 Reviewed and updated list of employees & changed from
MSDS to SDS per DCR 001602.
E: 10/01/2020 Updated per DCR 001829
BMT 500 Rev. F 06-12-2024 3
1.0 SCOPE:
The provisions of this plan shall be carried out immediately whenever there is a
fire, explosion, or release of hazardous waste constituents, which could threaten
the environment or human health.
The waste treatment system is installed above grade and located outside the
manufacturing facility in a separate wing of the building. The system is
completely modernized, automated and equipped with alarm signals and controls
as required.
In case of fire, explosion, or discharge of hazardous waste to air, soil, or surface
water, all facility personnel will be instructed by intercom of any action to be
taken or to vacate the building through the nearest marked exit.
The Emergency coordinator or his delegate, will notify appropriate agencies such
as: Fire Dept., Police, Hazardous Material response teams, Ambulance, etc.
whenever their assistance is required
2.0 NOTIFICATION LIST:
The following Hospitals, Fire, & Police departments have been notified of the
Hazardous waste generated at this facility. Records of such notification(s) are
available on site.:
HOLY CROSS HOSPITAL - JORDAN VALLEY WEST 801-964-3600
UNIVERSITY MEDICAL CENTER 801-581-2291
ST. MARKS HOSPITAL 801-268-7129
SALT LAKE CITY POLICE DEPT. 801-799-3000
SALT LAKE CITY FIRE DEPT. 801-799-4231
STATE OF UTAH DEPARTMENT OF HEALTH
DIVISION OF ENVIRONMENTAL HEALTH 801-313-6641
For large unmaintainable spills, call:
THE NATIONAL RESPONSE CENTER 24/7 HOTLINE [phone]
BMT 500 Rev. F 06-12-2024 4
3.0 PLANT LAYOUT:
A Plant layout of all applicable areas of the Hazardous Waste Emergency
Contingency Plan will be hung in several areas in the shop for all employees to
use in case of an emergency.
This layout shall include a listing and location of the following as a minimum:
1. All fire extinguishers
2. ALL Exits
3. Safety equipment cabinets, Spill Kits Etc.
4. SDS sheets (location)
5. Tank numbers and index
6. Safety showers and eye wash
7. All main shut off valves, gas, water, sewer, electric
8. Water treatment plant
This layout shall be subject to review at least annually.
Location of all spill kits are marked on the Plant Layout. These kits are for small
spills. Use them to contain the spill into one specific area.
4.0 SAFETY EQUIPMENT AND LOCATION:
Safety equipment is stored in the Rectifier Room and is marked as such on the
plant layout. Also available by asking any of the Safety committee members or
your immediate supervisor.
Fire extinguishers are on hand for electrical and minor fires of all kinds.
These extinguishers are marked in red on the plant layout.
A shovel to transport spilled hazardous waste into drums is located in the
Safety Equipment Cabinet in the Rectifier Room.
Empty containers to facilitate hazardous waste are located outside under the
awning in the Hazardous Waste designated area, and are marked on the plant
layout.
Safety suit, boots, face shield, and long rubber gloves to handle hazardous
wastes shall also be kept in the safety equipment cabinet in the rectifier room
Incoming water lines into the electroplating area are equipped with solenoid
valves. These valves will shut off incoming water in case of power failure or
shall be manually tripped in case of discharge of hazardous waste.
A main shut off valve to the sewer line is located in the water treatment room
to prevent discharge of hazardous waste from the facility. This is marked on
the plant layout for easy accessibility.
A Completely stocked first aid kit is kept in the front office and is accessible
24 hours a day. This box is white and green and contains all bandages and
decontamination washes needed for cuts and scrapes of most kinds. Smaller
kits with bandages and smaller items for minor cuts are located in each shop.
BMT 500 Rev. F 06-12-2024 5
5.0 EMERGENCY COORDINATOR/HAZMAT COORDINATOR(S):
Specific functions are detailed in BMT 500-1
Chad Kerr – (801)-973-8966 Primary Emergency Coordinator
Steve Rij – (801)-550-4230 After Hours Emergency Coordinator
Kristy Madsen – [phone] 2nd After Hours Emergency Coordinator
Rich Madsen – Hazmat Co-coordinator
6.0 SPECIFIED PERSONNEL:
Only specified personnel, chosen by the emergency coordinators, shall be allowed
to make required additions to tanks. Other personnel shall be allowed to make
additions only under supervision of an emergency coordinator or someone
appointed by him. As of the revision date of this procedure, the following have
been approved to perform such task:
Chad Kerr
Kylie Hydrick
Ignacio (Nacho) Ramirez (Night Shift)
Guadalupe (Lupe) Chacon
Steve Rij
Dario Martinez
Bandie Chico
7.0 EMPLOYEE TRAINING:
Hazardous Waste Regulations of the state of Utah requires training every 3 years
for all personnel involved in the management, handling and signing manifests on
behalf of the company with regards to hazardous waste. At a minimum, this
RCRA training must cover the general requirements, function specific, safety and
security as outlined in 49 CFR 172.704, including manifesting, waste analysis,
and emergency response. Training materials, training roster and exam results
showing certification shall be made available upon request by appropriate
agencies.
Facility personnel shall also be trained annually. This training shall be conducted
by a person trained in hazardous waste management procedures. Facility
personnel shall be trained with the knowledge to respond effectively to
emergencies by familiarizing them with emergency procedures, emergency
equipment, and emergency systems including: waste feed & sewer shut off
systems, communications and/or alarm systems, response for fires and explosions,
response to ground water contamination, and shut down operations.
EMPLOYEE TRAINING OUTLINE:
All facility personnel shall successfully complete a program of classroom
training or on the job training that teaches them to perform their duties in a
way that will ensure their safety and others they work with. This program
BMT 500 Rev. F 06-12-2024 6
shall be directed by a person or persons trained in hazardous waste materials
management procedures as follows:
A. All employees shall attend classroom training yearly.
B. All employees shall demonstrate proficiency in handling hazardous materials.
a. Classroom training shall include all applicable areas of the emergency
contingency plan.
b. Classroom training will entail learning locations and markings of
safety cabinets, fire extinguishers, garage door exits, fire hoses, and
first aid kit on the plant layout. Additionally, pouring flammable
liquids, how to read the company plant layout and where to shut off all
main valves.
c. After D.O.T. classroom training, the employee shall demonstrate
his/her knowledge by completing a test passing with at least a 70%.
d. All employees shall know who to call in case of an emergency and/or
demonstrate how to find who to call (lists posted by all company
phones).
CLASS OUTLINE
HMIS and SDS Right To Know:
1. Explain the SDS and HMIS systems and what it entails.
a. All incoming chemicals must be identified and labeled per BMT 501
and according to the SDS sheet that was supplied with that chemical.
b. Because the chemical manufacturers of the certain chemical have the
most knowledge of all details and hazardous ingredients of that
chemical, they must provide SDS sheets to their customers upon
request. These sheets must be correct to the best of their knowledge.
2. Explain the rating system and personal protection rating:
a. The basics for the Health Hazard Rating is based on the acute toxicity
of the chemical. Acute toxicity refers to the effects that are evident
shortly after exposure to a hazardous material such as, rashes, burns,
etc. This is measured on a scale of 0-4, 0 = minimal hazard, 4 = severe
hazard.
b. The Flammability Rating is based on the flashpoint of the material.
This is also measured on a scale of 0-4 as outlined below. The
flashpoint is the minimum temperature needed to ignite the chemical.
0 = Any material that will not burn in air at 1500ºF for 5 minutes.1 =
All materials having a flashpoint of 200ºF or more. 2 =
Liquids having a flashpoint above 100ºF but not over 200ºF Materials
that readily give off flammable vapors). 3 =
Materials with a flashpoint below 73ºF and boiling point of 100ºF and
above. These materials are capable of ignition under almost all
normal temperature conditions. 4 =
Very flammable gases or very (volatile) flammable liquids with a
BMT 500 Rev. F 06-12-2024 7
flashpoint below 73ºF and boiling point below 100ºF.
c. The Reactivity Rating is based on the ability for the chemical to react
with other chemicals, water, heat, or pressure. Also measured by a 0 –
4 rating.
d. The Personal Protection Rating is supplied by the chemical
manufacturer. It describes exactly what type of equipment should be
used when handling certain types of chemicals. This is done by an
alphabetical rating A-K describing which equipment to use, and is
designated on supplied wallet cards (everyone must have wallet cards
on hand). An X means that before you handle that chemical your
supervisor must be notified and asked for special handling instructions.
3. Discuss SDS sheets explaining in detail what is located on the SDS sheet and
where it is located. (Sample HCL SDS are utilized for this activity). Any
questions are answered.
4. Wallet cards will be supplied to employees that do not have them.
5. A detailed explanation of where to find and how to read all SDS sheets on site,
specifically:
a. Located in safety cabinet outside plating shop supervisor office
b. Front office (Original copies of all SDS)
c. All SDS are current and available for every chemical on site.
6. Any other applicable videos may be shown.
7. Any additional questions are answered at this point.
8. HMIS/SDS quiz will be administered to all employees. These quizzes must be
dated and signed by the employee.
HAZARDOUS WASTE TRAINING OUTLINE:
Explain what hazardous waste is: any substance that can endanger any living
thing or contaminate ground water or sewer systems.
Types of hazardous waste.
a. Reactive waste – EXAMPLE: Sulfuric, Chromic & Nitric Acid
b. E P Toxic (Extraction Procedure) waste – EXAMPLE: Solid waste
from water treatment plant.
c. Corrosive waste – EXAMPLE: All acids, caustic soda, etc.
d. Flammable waste – EXAMPLE: Paint, thinners, oils, etc.
BMT 500 Rev. F 06-12-2024 8
Types of possible hazardous waste, by department, at Blanchard Metals
Processing:
A. Machine Shop:
a. Coolant or oil spill treatment:
1) Contain to immediate area.
2) Use floor dry materials, then sweep up and dispose of in
clearly designated containers.
b. Spilled paints and thinners treatment:
1) Vent area as well as possible.
2) Use absorbent materials (paper towels, cloth or floor dry) to
clean up containment.
3) Place contaminated rags or materials in clearly designated
metal drum with lid.
B. Plating Shop:
a. In case of leaking drum:
1) Contain spill to immediate area by the use of spill kit and
burms.
2) Contact Emergency Coordinator.
3) With the help of the Emergency Coordinator, pump the
drum into another container or if material is leaking too
fast, use the salvage drum. (It is big enough to hold the
entire drum).
4) Do not attempt to move a drum to another area until the
problem is resolved.
b. In case of an acid based chemical spill:
1) Contain to immediate area with spill kit using socks and
berms.
2) Contact the Emergency Coordinator
3) Anyone helping in clean up should put on proper breathing
device.
4) Then, with caution, use soda ash to absorb chemical. (Soda
ash, when mixed with acids, produces carbon dioxide gas
and will generate heat). USE CAUTION!!!!!!
5) Sweep up and dispose of in clearly designated PLASTIC
container.
c. In case of chemical tank leakage:
1) Contact the Emergency Coordinator
d. Dry chemical spills:
1) Salvage what chemical you can (do not use water to wash
away).
2) Sweep up the rest of the chemical and alert the Emergency
Coordinator for disposal.
C. Heat Treat Shop:
a. Heat Treat Oils:
1) Use floor dry to absorb
BMT 500 Rev. F 06-12-2024 9
2) Sweep up and put in clearly designated drum.
D. Water Treatment Room:
a. Solid hazardous waste spill:
1) Contact the Emergency Coordinator
2) Waste should be shoveled up and put in clearly designated
bulk bag (super sack) and/or plastic drum.
b. If you smell a Chlorine or Sulfur Dioxide leak:
1)Do not enter the room!
2) Contact the Emergency Coordinator
3) Vent room
4)Put on proper breathing device before entering room.
5) Leaks may be found by using Ammonia. (Ammonia will
smoke where gas is leaking).
6) Turn off all equipment until damage is repaired.
Chemical contamination to the body:
a. Most common ways for chemical to enter your body are:
1) Breathing
2) Eating (There will be no eating in the shop area. This will
be strictly enforced).
3) Skin, through pores and under nails or scrapes.
In case of fire in a waste storage area, you should:
a. Turn on an alarm to warn anyone that may be affected.
b. If fire is too large for you to contain, call 911 and report the fire.
c. Contact Emergency Coordinator.
What to do in case of a major emergency or hazardous waste spill:
a. Call 911 and report the emergency.
b. Contact Emergency Coordinator and they will coordinate any
action that may be required.
Handling of all chemicals
a. All raw chemicals will be handled by authorized employees with
special training in safe chemical handling.
Any person emptying a raw chemical barrel or drum of any kind should
completely rinse and clean all chemicals from container before removing it
from the building.
8.0 FIRE CLASS OUTLINE FIRES:
1. There are 4 types of fires:
a. Class A – Wood, plastic and paper products.
b. Class B – Flammable liquids and combustible liquids.
c. Class C – Electrical fires
BMT 500 Rev. F 06-12-2024 10
d. Class D – Combustible metals (Titanium)
2. The best extinguishing agents for each class of fire are:
a. Class A - Water, dry chemical.
b. Class B - Dry chemical, Carbon Dioxide (No water shall be used,
fire will spread).
c. Class C - Dry chemical, Halon, Carbon Dioxide (No water shall be
used as electrocution could occur).
d. Class D – Sand, special materials, foam
3. Identifying the different types of fire extinguishers:
a. Carbon Dioxide – has a large nozzle
b. Dry chemical - has small nozzle
c. Water – stainless steel container (no water extinguishers at BMP)
4. Things you should know about fire extinguishers:
a. Most extinguishers will only last 8 -30 seconds
b. You should always hold a fire extinguisher in an upright position.
Some water extinguishers are an exception).
5. What to do in case of a fire:
a. You should sound an alarm to warn other people by way of an
intercom, shouting, or other alarm devices if available.
b. If there is any doubt in your mind, call the fire department/911.
6. When attempting to put out a fire with an extinguisher:
a. Always approach fire from the upwind side.
b. Point the fire extinguisher at the base of the fire, moving back and
forth.
c. If you are unable to put out the fire, call emergency phone 911,
then contact your Emergency Coordinator(s).
d. Even if you able to put out a fire, call your Emergency
Coordinator. He/she will determine which steps to take next.
e. If the fire is around hazardous waste or chemicals that might burn,
use extreme caution – it may give off fumes that could be fatal to
you. Do not try to put out the fire yourself. You should call your
Emergency Coordinator and/or the fire department/911.
7. The handling and knowing of flammable and combustible liquids:
a. A flammable liquid is a low temperature igniting liquid that will
ignite at 200ºF or less.
b. Combustible liquids are liquids that will ignite at 200ºF and
above. A good example are diesel fuel and oils.
c. When you are pouring a flammable liquid you should always
ground both containers. The reason for this is that the drum/can
you are pouring from causes friction that could ignite the liquid.
BMT 500 Rev. F 06-12-2024 11
8. What to do in case of a flammable liquid spill:
a. Make sure the area where the spill happened has been well
ventilated.
b. Contain the spill to the smallest area possible using sand bags, sand
or floor dry to clean up the spill, then put the material into a
specially marked container. (-CONTAMINATED FLOOR DRY-)
c. Do not use a steel shovel to clean up the spill. A spark can still
ignite the material.
d. One gallon of flammable liquid that has been spilled on the ground
equals up to 600 gallons of vapor before it evaporates (the vapor
will ignite).
e. Combustible liquids are much safer to handle than flammable
liquids because of their high flashpoint.
9.0 PREPAREDNESS AND PREVENTION:
Blanchard Metals will be equipped with the following required equipment:
1. An internal communications or alarm system capable of providing immediate
emergency instruction (voice or signal) to facility employees.
2. A device capable of summoning external emergency assistance from local law
enforcement agencies, fire departments, or state or local emergency response
teams, such as telephone (immediately available at the scene of operations) or
a cell phone/hand held two-way radio.
3. Portable fire extinguishers, fire control equipment (including special
extinguishing equipment, such as that using foam, inert gas, or dry chemicals),
necessary safety equipment, discharge control equipment, and
decontamination equipment.
4. Water at adequate volume and pressure to supply water hose streams, or foam
producing equipment, or automatic sprinklers, or water spray systems.
10.0 TESTING AND MAINTENANCE OF EQUIPMENT:
All facility communications or alarm systems, fire protection equipment,
discharge control equipment, and decontamination equipment, where required,
shall be tested and maintained as necessary to assure its proper operation in
time of emergency.
11.0 ACCESS TO COMMUNICATIONS OR ALARM SYSTEM:
1. Whenever hazardous waste is being poured, mixed, spread or otherwise
handled, all employees involved in the operation shall have immediate access
to an internal alarm or emergency communication device, either directly or
through visual or voice contact with another employee, unless the facility
emergency coordinator has judged that such device is not required.
BMT 500 Rev. F 06-12-2024 12
2. If there is ever just one employee on the premises while the facility is
operating, he shall have immediate access to a device capable of summoning
external emergency assistance, such as a telephone (immediately available at
the scene of operation) or a cell phone/hand held two-way radio, unless the
facility emergency coordinator has ruled that such a device is not required.
12.0 REQUIRED AISLE SPACE:
Aisle space shall be maintained to allow the unobstructed movement of
personnel, fire protection equipment, discharge control equipment, and
decontamination equipment to any area of the facility operation in an
emergency. Aisle space for stored hazardous waste, as well as all central
accumulation areas, shall be sufficient to allow for weeklyinspections
13.0 HAZARDOUS WASTE CONTENT:
The hazardous waste produced at Blanchard Metals Processing Company is in
solid waste form after treatment. It consists of heavy metals produced as by-
products from metal plating. The color of the waste is gray, and has hardly
any odor. It is classified as F006 waste.
14.0 PLAN REVIEW:
This plan shall be reviewed annually and/or amended as necessary. Any
major changes will be forwarded to all parties concerned.
15.0 EMERGENCY COORDINATOR DUTIES AND PROCEDURES:
At all times, there shall be at least one employee either on the facility
premises or on call with the responsibility for coordinating all emergency
response measures. This person shall be thoroughly familiar with all aspects
of the facility’s contingency plan, all operations and activities at the facility,
the location and characteristics of waste handled, the location of all records
within the facility, and the facility layout. In addition, this person shall have
the authority to commit the resources needed to carry out the contingency
plan.
16.0 EMERGENCY PROCEDURES:
1. Whenever there is an imminent or actual emergency situation, the emergency
coordinator shall immediately:
a. Activate internal facility alarms or communication systems, where
applicable, to notify all facility personnel.
b. Employees are annually trained to quickly, calmly & safely exit
the building and meet in designated area(s), determined by their
employee number as follows:
BMT 500 Rev. F 06-12-2024 13
a. 100’s – Far Southeast corner of the parking lot,
b. 200’s – Center of the parking lot,
c. 300's – Far Northeast corner of the parking lot,
d. 500’s – In front of the building (Director’s Row)
c. Notify appropriate state or local agencies with designated response
roles whenever their assistance is needed.
2. In the event of a discharge, fire, or explosion, the facility’s emergency coordinator
shall immediately identify the character, exact source, amount and actual extent of
any discharged materials. He may do this by observation and/or review of facility
records or manifests and if necessary by chemical analysis.
3. Concurrently, the facility’s emergency coordinator shall immediately assess
possible hazards to the environment or human health that may result from the
discharge, fire, or explosion. This assessment shall consider both direct and
indirect effects of the discharge, fire, or explosion (i.e., the effects of any toxic,
irritating, or asphyxiating gases that are generated, or the effects of any hazardous
surface water run-offs from water or chemical agents used to control fire and heat
induced explosions).
4. If the emergency coordinator determines that the facility has had a discharge, fire
or explosion which could threaten human health, or the environment outside the
facility, he/she shall report his findings as follows:
a. If his assessment indicates that evacuation of local areas may be
advisable, he shall immediately notify appropriate local authorities.
He/she shall be available to assist the appropriate officials in
making the decision whether local areas should be evacuated.
b. He/she shall immediately notify either the government official
designated as the on-the-scene coordinator for our geographical
area, the National Response Center (using their 24-hour toll free
number 1-800-424-8802) and the Division of Waste Management
and Radiation Control at 801-536-0200 or after hours at 801-536-
4123).,). The caller must report:
1) Name and telephone number of reporter
2) Name and address of facility
3) Time and type of incident (e.g., discharge, fire)
4) Name and quantity of material (s) involved, to the extent
available.
5) The extent of injuries, if any
6) The possible hazards to human health, or the environment,
outside the facility.
5. During an emergency, the facility’s emergency coordinator shall take all
reasonable measures necessary to ensure that fires, explosions, and discharges do
not occur, recur, or spread to other hazardous waste at the facility. These
measures shall include, where applicable, stopping processes and operations,
collecting, containing discharged wastes and removing or isolating containers.
BMT 500 Rev. F 06-12-2024 14
6. If the facility stops operations in response to a discharge, fire, or explosion, the
facility’s emergency coordinator shall monitor for leaks, pressure buildup, gas
generation, or ruptures in valves, pipes or other equipment, where appropriate.
7. Immediately after an emergency, the facility’s emergency coordinator shall
provide instruction for treating, storing, or disposing of recovered waste,
contaminated soil or disposing of recovered waste, contaminated soil or surface
water, or any other material that results from a discharge, fire, or explosion at the
facility. Unless the owner or operator can demonstrate that the recovered material
is not a hazardous waste, the owner or operator becomes a generator of hazardous
waste and shall manage it in accordance with all applicable requirements imposed
by state and federal laws and regulations.
8. In the event of an accidental discharge or “Slug Load” to the sewer, notify the
POTW immediately during normal work hours 7:00-5:00 at 801-799-4000 or 801-
799-4041 and after hours at 801-799-4032, 799-4031 or cell 558-6056. The
notification shall include: location of the discharge, contact person and phone
number, SDS on type of waste, volume and corrective actions or other pertinent
information related to the discharge. All three in house emergency coordinators
must be notified.
9. The facility’s emergency coordinator shall ensure that, in the affected area(s) of
the facility:
a. No waste that may be incompatible with the discharged material is
treated, stored, or disposed of until cleanup procedures are
completed.
b. All emergency equipment listed in the contingency plan is cleaned
and fit for its intended use before operations are resumed.
10. The facility owner or operator shall record the time, date, and details of any
incident that requires implementing the contingency plan. Within 5 days after the
incident, he shall submit a written report on the incident to the committee or its
duly appointed representatives, and forward a copy to the WMRC Director (see
Section 16.0, 4 b.) within 15 days.The report shall include:
a. Name, address, and telephone number of the owner or operator
b. Name, address, and telephone number of the facility
c. Date, time and type of incident (e.g., fire, etc.)
d. Name and quantity of material(s) involved
e. The extent of injuries, if any
f. An assessment of actual or potential hazards to the environment or
human health, where applicable
g. Estimated quantity and disposition of recovered material that
resulted from the incident.
h. Cause of the discharge, and the measures to be taken to prevent
future occurrences.
11. The facility owner or operator shall notify the committee, or its duly appointed
representatives, and appropriate state and local authorities, that the facility is once
again in compliance before operations are resumed in the affected area(s) of the
facility.
BMT 500 Rev. F 06-12-2024 15
17.0 REQUIRED IN-HOUSE INSPECTIONS:
1. Daily and weekly inspections shall be accomplished, per the following schedules,
for compliance.
a. Waste Water Treatment Unit (Daily Inspection):
1) pH recorder and controls
2) Warning Lights & Alarm controls
3) Feeder pumps & supply pumps
4) General Operation of the unit
b. Waste Water Treatment Unit (Weekly Inspection):
1) All piping and fittings for leaks
2) Deterioration of equipment (rust, etc.)
3) Filter press operation and cleanliness
4) Solenoid valve operation on water supply
18.0 WASTE RECYCLING AND DISPOSAL TECHNIQUES USED AT B.M.P.
1. Lamp Recycling
Whenever possible the maintenance department shall replace the mercury
containing bulbs with new phosphorous lamps to alleviate the need to recycle.
When recycling is required, Onyx Environmental via Grainger Industrial
Supply. Containers will have preprinted address labels, waste pickup and
transportation information. Once containers have been filled with the spent
bulbs, call the toll free # on the container for pickup. A certification of
recycling will be kept on file.
2. F006 Solid Waste from Electroplating Solutions:
Solid & liquid waste produced from electroplating operations will be recycled
whenever possible for the heavy metals that are present in the waste.
Bulk bags 48” x 48” x 48” and approved 55 gallon drums will be used to store
and transport the waste offsite to an authorized location, determined by
transporter, for recycling/disposal.
This hazardous waste may be held on site for a maximum of 90 days. F006
shall be labeled with the accumulation start and end date. 55 gallon drums
shall be labeled with contents and date it was classified as hazardous waste.
Both F006 & liquid waste must be stored on containment pallets in designated
area and company hazardous waste coordinator notified.
Satellite collection drums are located in the plating shop. They shall remain
closed when not in use and transported to authorized location when full.
Blanchard Metals currently utilizes AET Environmental as a transporter and
liaison for the recycling of the waste produced.
All manifests are kept with hazardous waste coordinator.
BMT 500 Rev. F 06-12-2024 16
3. Paint disposal and/or recycling:
Whenever possible, Blanchard Metals will use the expired paint from
production operations as maintenance paint to paint equipment and/or
buildings.
When disposal is necessary, the expired cans will be left open, allowed to dry
to a solid mass, then disposed of as a solid waste at the Salt Lake Valley
Landfill located at 6030 West California Avenue.
Paints that cannot be disposed of at the landfill will be manifested and
transported by AET Environmental for appropriate recycling/disposal.
All manifests are kept with hazardous waste coordinator.
4. Spent/Used M.E.K.
Blanchard Metals uses M.E.K. to clean parts prior to process & to clean paint
equipment.
Cotton swabs used for cleaning parts are F005 hazardous waste exempt and
shall be disposed of in properly labeled “Justrite” containers at the point of
use; no general refuse discarding allowed. When the plastic liner (garbage
sack) is full, and prior to discarding, verify that no free liquids are present. If
free liquid is present, it shall be discarded of in the satellite M.E.K. drum
located in the machine shop; otherwise, tie sack shut and dispose of in
dumpster where it will be disposed of at the Salt Lake Valley Landfill located
at 6030 West California Avenue.
Once the satellite M.E.K. drum reaches 55 gallons, the drum must be
transferred to the hazardous waste Connex within 3 days and then must be
transported within 90 days by AET Environmental.
All manifests are kept with hazardous waste coordinator.
19.0 FINAL COMMENTS:
The information contained in this procedure is correct and accurate, to the best
of our knowledge, via conversations with officials at the state level and by
inquiries into the OSHA, EPA and RCRA websites at the time of the revision
date on this document.
BMT 500-1 Rev. E 06/12/24 (Maintained by Q.M.)
BLANCHARD METALS PROCESSING CO.
A Utah Corporation
BMT 500-1
PURPOSE:To inform all personnel those team members authorized by the
Company to handle &/or move Hazardous Waste.
SCOPE:
All employees are to be trained annually on the do’s and
don’ts of Hazardous Waste.
Key personnel listed below shall be trained annually by
outside agency (RCRA training)
o Key personnel shall be familiar with BMT 500
Contingency Plan) as well as location of all spill kits
and emergency shut off valves.
o Initial training will consist of a 2-hour class room
followed by a 1 hour “hand’s-on” walk through shop
training.
o Annual training will consist of approx. 1-2 hours of
classroom and ½ hour walk thorough.
DOT “Hazmat” employee training shall be given every 3
years to assigned personnel.
KEY PERSONNEL:
Steve Rij, President: Hazmat co-coordinator. Oversees all
hazardous material generated at BMP and its proper
disposal. Emergency contact.
Rich Madsen, Quality Manager: Hazmat co-coordinator.
Oversees all hazardous material generated at BMP and its
proper disposal. DOT “Hazmat” Designee.
Kristy Madsen, Vice-President/General Manager:
Emergency contact.
Alfredo Valenzuela, Maintenance Supervisor: Responsible
for water treatment plant and solid waste collection.
Emergency contact.
Chad Kerr, Plating Shop Supervisor: Responsible for
transporting hazardous waste from shop to holding area for
disposal, Emergency contact & DOT “Hazmat” backup
Ignacio Ramirez, Plating Shop Supervisor Assistant (Night
Shift): Assists Plating Shop Supervisor as necessary.
Steven P. Rij, Project Coordinator: Assist in an emergency
trained to move waste.
Chris Rij, Production: Assist in an emergency & trained to
move waste.
Richard Dickerson, N.D.T. Production: Assist in an
emergency & trained to move waste.
Tony Garcia, Quality: Assist in an emergency & trained
on do’s and don’ts of Hazardous Waste for training.
Jeff Velasquez, Quality: Assist in an emergency & trained
on do’s and don’ts of Hazardous Waste for training.
BLANCHARD DOT
TRAINING
Daniel E Nye, MSPH, CIH
Given 6-21-2024
Department of Transportation
US Department of Transportation
DOT Overview / Agenda
What is a Haz-Mat?
Why is Blanchard Affected?
What are the Training Requirements?
What is a Hazardous Waste Manifest
What is a HazMat?
A “hazardous material” is a substance or material that has
been determined to be capable of posing an unreasonable risk
to health, safety and property when transported in commerce.
There are many laws governing the manufacturing, use,
storage, transport and disposal of HazMats.
There are different agencies of government that control each
of those aspects.
What is a HazMat?
Government agencies that control hazardous materials:
Environmental Protection Agency (EPA)
Disposal and Storage
U.S. Department of Transportation (USDOT)
Transport
Occupational Safety and Health Admin. (OSHA)
Safety during use / Hazard Communication
Process Safety Management
Why is Blanchard Affected?
Government agencies that control hazardous materials require training for
certain employees:
Environmental Protection Agency (EPA)
Disposal of “Hazardous Waste”
RCRA Training
U.S. Department of Transportation (USDOT)
Hazmat employees
More employees than you would think…
Occupational Safety and Health Admin. (OSHA)
Safety during use / Hazard Communication
Other training sessions
Why is Blanchard Affected?
What is a Hazmat Employee?
A person who is employed by a hazmat
employer and who in the course of
employment directly affects hazardous
materials transportation safety.
Why is Blanchard Affected?
What is a Hazmat Employee?
This term refers to an individual, including a self-employed
individual who, during the course of employment:
Loads, unloads, or handles hazmat;
Tests, reconditions, repairs, modifies, marks, or otherwise
represents containers, drums, or packagings as qualified for
use in the transportation of hazardous materials;
Prepares hazardous materials for transportation;
Is responsible for safety of transporting hazardous
materials; and
Operates a vehicle used to transport hazardous materials.
What are the Training Requirements?
Safety training (already covered);
General awareness training (this session);
Function specific training (already covered); and
Recurrent training. “A hazmat employee shall receive the
training required by this subpart at least once every three
years.”
HAZARDOUS MATERIALS
Shipping & Receiving Requirements
All hazardous materials must be
prepared in accordance with the
appropriate federal Hazardous
Materials Regulations found in
Title 49 CFR (Transportation)
HAZARDOUS MATERIALS
Shipping & Receiving Requirements
Hazardous material must be properly classed, described, packaged,
marked, labeled, and in condition for shipment;
Ensure that the material offered for shipment is neither “forbidden”
nor “prohibited” from transportation;
Know exactly what you are shipping and receiving - If in doubt
STOP.
At Blanchard, this process has already been performed when
each material offered for shipment was “PROFILED” by the waste
contractor. Blanchard is responsible for using the correct labels,
markings, and packaging.
This is discussed in detail on the next slides…
CLASSIFICATION AND DESCRIPTION OF MATERIALS
Application of applicable regulations begins with
classification of the material, and was performed
by Blanchard / Hauler
Hazardous Materials are grouped into 9 primary
hazard classes
Some of these hazard classes have subdivisions
Properly describing a hazardous material not only
communicates the presence of a hazardous
material, but also establishes the specific emergency
actions to take in an emergency
DESCRIPTION OF MATERIALS
The Hazardous Materials Table
The HMT Table describes the requirements that
apply to each shipment of hazardous material(s)
The description includes:
Proper shipping name
Hazard class or division number
Identification number
Material Classification
The Hazardous Materials Table
The shipping description must appear on the Shipping Paper in the
exact proper sequence as shown in the Hazardous Materials Table
Shipping Materials
Remember, we already discussed how we choose
labeling and packages (drums/containers):
Profile Numbers
Product Waste Management Forms / Hauler Profile
PROPER SHIPPING NAME: “UN1549, Waste Antimony
Compound, Inorganic, Solid, NOS, 6.1, PGIII”
Shipping Materials
Remember, the labels we
choose have Hazard
Classes from the HM Table
marked
The following slides
describe each of the
Hazard Classes that you
may encounter
Material Classification
HAZARD CLASSES
Class 1: Explosives
Class 2: Gases
Class 3: Flammable Liquids
Class 4: Flammable Solids
Class 5: Oxidizing Substances
Class 6: Poisons
Class 7: Radioactive Materials
Class 8: Corrosive Materials
Class 9: Miscellaneous Hazardous
Materials
Material Classification
Class 1 - Explosive Hazards
Explosions are very fast chemical reactions which release
large quantities of gas.
Explosives include:
sporting ammunition;
blasting charges and detonators; and
Fireworks.
Material Classification
Class 2 - Compressed Gases
A compressed gas has a physical hazard due to the increased
pressure under which the chemical is maintained.
Compressed gases include:
Oxygen;
Nitrogen;
Compressed air;
Acetylene;
Material Classification
Class 3 - Flammable Liquids
Flammable liquids, as the name
implies, are liquids which burn.
Flammable liquids include:
Gasoline;
Alcohols; and
Solvents such as benzene.
Material Classification
Class 4 - Other Flammable Hazards
Other flammable hazards include:
flammable solids;
self-reactive substances; and
substances which, in contact with water, emit
flammable gases.
Material Classification
Class 5 - Oxidizers/Organic Peroxides
These are chemicals which will
accelerate combustion.
Examples include:
sodium chlorate;
hydrogen peroxide; and
benzoyl peroxide.
Material Classification
Class 6 - Toxic & Infectious Agents
Health hazards include those products
and materials which have an adverse
effect on humans and animals.
Examples include:
Nicotine
Pesticides;
Tissue/blood samples.
Material Classification
Class 7 - Radioactive Materials
Material Classification
Class 8 - Corrosives
Corrosive materials will react
chemically with steel, aluminum or
skin.
Examples include:
acids such as hydrochloric;
alkaline materials such as sodium hydroxide; and
gases such as chlorine and ammonia.
Material Classification
Class 9 - Miscellaneous Hazards
Don’t readily fall into the other
categories.
Examples include:
Substances with noxious odor;
Substances that are hazardous to the
environment
Substances which are magnetic; and
Dry ice.
PACKAGING REQUIREMENTS
Packaging must be sufficient to ensure containment
of the material throughout transportation.
Once again, packaging assessments have been
performed for us in the form of profiles from the
waste hauler
All Packaging MUST
Meet DOT requirements
Marked with the proper shipping name
ID number
Tested & approved prior to use
Include manufacturer’s marking
We should use DOT-approved
containers only for shipping Haz-Mats.
PACKAGING REQUIREMENTS
Manifest Reviews and Field OJT
Examples
Review latest manifests
Review waste shipping descriptions
Review containers used
Review manifest signature requirements:
Correct label/name on container (Unxxxx, Waste Material, hazard
number, Packing Group.
Correct hazard labels on containers, correct weights/quantities
Example Shipping Names
UN3264, Waste Corrosive Liquid, acidic, inorganic, n.o.s.
Hydrochloric Acid), 8, PGII
Signatures: Signature for the company, example
Sign as “Name, for BMP”, example – Chad Kerr, for BMP
The item in RED is the Identification Number:
UN1558, Waste Arsenic, 6.1, PG II
A.True
B.False
Which of the following is the correct order for
a proper shipping name?
A.PGII, Waste Methanol, 3, UN1230
B.3, Waste Methanol, UN1230, PGII
C.Waste Methanol, PGII, 3, UN1230
D.UN1230, Waste Methanol, 3, PGII
The picture below depicts which hazard class?
A.Dangerous
B.Poison Gas
C.Poison Solid
D.Infectious Substance
Proper containers can be selected using both
the HMT and the…
A.UN Container Rating
B.Supplier Agreement
C.US DOT Container Rating
D.Subway Sandwich
I need DOT training every…
A.Every year
B.Every 2 years
C.Every 3 years
D.Every 5 years
I should either contact my supervisor
immediately or initiate the emergency response
program in the event of a hazardous spill?
A – True
B - False
The proper shipping label for a drum of
hazardous waste would indicate the hazard of
the material and the UN shipping description?
A.True
B.False
BLANCHARD METALS PROCESSING CO.
A Utah Corporation
Training Attendance Documentation Sign-in
Date: June 21, 2024
Time: 1300
Subject: D.O.T. Training
Location: BMP Conference Room
Print Name
Y-v\ \.AA D2
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Trainer: Dan Nye, RME-------
Comments:
Form# 6000 Rev. A 11/05/2010
BLANCHARD METALS PROCESSING CO.
A L,tah Corporation
Training Attendance Documentation Sign-in
Date: June 21, 2024
Time: 1430
Subject: Annual Hazardous Waste Training
Location: BMP Conference Room
Comments:
Print Name
ls\!\ ti Aj)S8J ____ _
Ws __ ?? _J _________________
Y<-Pf -'1.tffi2-_vV£ L ---
2.L'd cd.fl rkrutJ-----
l.c,_.:;_1-""'".:::'--"------
tit,":JO i/4urrz-£"i,.,.<-\
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Form# 6000 Rev. A 11/05/2010
Paint
Shop
Weld
Shop
Locker Room
Mach.
Shop
Office Lunch Room Laboratory
Plating
Office
File
Room
Inspection
Mag
Particle
Inspection
Salt Spray &
Humidity
Chambers
Front
Office
Office
Office
Office
Storage Masking Area Quality
Office
Air
Compressor
Water Treatment Plant
Chrome
Scrubber
Shot Peen &
Blast Area Bag house &
Swedebrator
Rest Rooms
Shipping & Receiving
17A
18
19
20
22
23
39
38
24
25
26
30
31
32
33
34
35
36 40
41
42
43
44
45
46
47
48
49
50
53
54
55
51
52
67
73
72
71
70
69
68
66
63
62
59
58
57
80
81
82
83
84
85
86
87
88
89
90
Water
Treatment
Separation
Sumps
204
206
245
24
4
260
325
321
210
205
Rectifier Room
SHOT PEEN STORAGE DRY CHEMICAL STORAGE
SMALL SECONDARY CONTAINMENT
MAINTENANCE PARTS STORAGE
203
302 304
305
22
5
56
100A
240 V Main
Power Box
48
0
V
P
O
W
E
R
GA
S
M
ETE
R
22
2
22
0
MP
3A
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P3
9
01
9
02
9
04
925
934
906
934
91
3
9
15
91
9
253 255
236
237
STORAGE
FLAME
HARDEN
254
BRUSH
CAD
VAPORDEGREASER
OXYGEN
ST2
924
913
920
EXIT
EXIT
EXIT
EXIT
EMERGENCYEXITMAINENTERANCE / EXIT
PLATINGSHOPMACHINESHOP HEAT TREAT
PROPANE
EXIT
251
252
228
233
227
226
250
HT.
OFFICE
208
256
216
224
234
235
214
HARDNESS
INSPECT
HARDNESS
INSPECT
137
136
135
134
133
132
131
130
152
153
409
408
407
406
405
404
403
402
401
400
427
426
425
424-A
424
423-A
423
422
421
420
BARREL
123
124
125
126
127
121
121-A
92
93
94
95
96
97
98
99
91
101-1
101-2
103-A
104
103
105
106
107
108
109
1
2
3
4 8
6 5
7
9
10
11-A
12
15
16
16-A
17
STORAGE
HAZ
STORAGE
FIRE EXTINGUISHER
FIRST AID STATION
EYE WASH STATION
GAS SHUT OFF
MAIN POWER SHUT OFF
GARAGE DOOR
STORM DRAIN
DUMPSTER
BLANCHARD METALS PROCESSING
REV. I 2024
207
201 202
209
217
916
TEMP / HUM. CONTROL
ROOM
FAROARM
X-RAY
C3H8
FILL
SPENT
OIL
LN2
RACKING
RECTIFIER
53
64 65
60
61
75
FILTER CAKE STORAGE
217
144
145
146
147
148
190
436
191
128
129
189
186
187
188
195
TABLE
194
193
192
240 242
SPILL KITS
TESTING
AND
INSPECTION
BLANCHARD METALS PROCESSING
EST. 1967SLC. UT.
SATELLITE MEK STORAGE